United States v. Livingston Samuels
713 F. App'x 897
11th Cir.2017Background
- Defendant Livingston Samuels appealed convictions for importation (21 U.S.C. § 952) and possession with intent to distribute cocaine (21 U.S.C. § 841).
- Five kilograms (5.083 kg) of cocaine were concealed inside souvenirs Samuels brought from Jamaica; DEA valued the shipment at $150,000–$160,000.
- Samuels testified he purchased the souvenirs from an unknown street vendor named “Ross” for $70 and denied knowledge of drugs; he gave explanations the government challenged as implausible.
- The government relied on circumstantial evidence (large quantity/value, hidden concealment, inconsistencies in Samuels’ account, credibility issues) to establish knowing possession and importation.
- The district court denied Samuels’ motion for judgment of acquittal; the Eleventh Circuit reviewed that denial de novo and assessed whether a reasonable jury could find guilt beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove knowing possession/importation | Government: circumstantial evidence (quantity, concealment, credibility) supports inference of knowledge | Samuels: hidden compartment + plausible, uncontradicted account required additional evidence of knowledge; no such evidence produced | Affirmed — reasonable jury could infer knowledge from quantity, concealment, and credibility issues |
| Role of hidden compartment in inferring knowledge | Government: hidden concealment does not preclude inference from circumstantial evidence | Samuels: hidden compartment cases require more than quantity to infer knowledge (relies on Ayala-Tapia) | Court: rejected a special rule; hidden compartments do not categorically require extra evidence; context controls |
| Weight of defendant’s testimony | Government: jury may disbelieve defendant; disbelief can be substantive evidence | Samuels: his testimony was plausible and uncontradicted on cross | Court: jury credibility determinations permitted; disbelief supports conviction |
| Standard of review for judgment of acquittal | N/A | N/A | Denial reviewed de novo; conviction stands if reasonable juror could find guilt beyond a reasonable doubt |
Key Cases Cited
- United States v. Friske, 640 F.3d 1288 (11th Cir.) (standard for de novo review of denial of judgment of acquittal)
- United States v. Hansen, 262 F.3d 1217 (11th Cir.) (view facts in light most favorable to government on sufficiency review)
- United States v. Rodriguez, 218 F.3d 1243 (11th Cir.) (upholding denial of acquittal if reasonable trier of fact could convict)
- United States v. Farley, 607 F.3d 1294 (11th Cir.) (conviction sustained if reasonable basis in record)
- United States v. Poole, 878 F.2d 1389 (11th Cir.) (elements of § 841 possession with intent)
- United States v. Vera, 701 F.2d 1349 (11th Cir.) (elements of § 952 importation; direct or circumstantial evidence may suffice)
- United States v. Quilca-Carpio, 118 F.3d 719 (11th Cir.) (hidden compartment in luggage; knowledge may be inferred circumstantially)
- United States v. Ayala-Tapia, 520 F.3d 66 (1st Cir.) (discusses inference of knowledge from quantity; did not create hidden-compartment rule)
- United States v. Brown, 53 F.3d 312 (11th Cir.) (jury may treat defendant’s disbelieved statements as substantive evidence of guilt)