United States v. PANZERA, 2:19-cr-00390

William Panzera was charged with conspiracy to distribute controlled substances and conspiracy to launder money, based on his involvement with Michael Action and Nicholas Araya, both admitted drug traffickers.
The evidence included testimony that Panzera facilitated the creation of sham companies (including Bella Hair and Stone Bridge Laboratory) to disguise drug-related payments and shipments.
Witnesses testified Panzera was aware of, or deliberately avoided learning about, the illegal nature of the transactions and used burner phones to avoid detection.
A jury trial concluded with Panzera convicted on both counts; he subsequently moved for acquittal under Rule 29 (insufficient evidence) or a new trial under Rule 33 (alleged error in jury instructions).
The trial court added a willful blindness instruction to the jury charge, prompted by government request and over Panzera’s objection.
The current decision addresses only post-trial motions, not the merits of the underlying substantive charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for conspiracy convictions	Evidence shows knowing participation	Evidence insufficient to prove knowledge or agreement to illegal objectives	Motion for acquittal denied
Use/timing of willful blindness jury instruction	Instruction appropriate; knowledge issue	Jury instruction was added late and used to improperly establish intent	Motion for new trial denied
Appropriateness of admitting Action’s "opinion"	Testimony was consistent with facts	Action’s subjective beliefs shouldn’t be admitted; conviction based on speculation	Argument not addressed/harmless error
Standard for granting new trial under Rule 33	No miscarriage of justice	Interests of justice require new trial due to errors in instructions	No exceptional case shown; motion denied

United States v. Boria, 592 F.3d 476 (3d Cir. 2010) (stating requirements to prove conspiracy: knowledge and agreement)
United States v. Mastrangelo, 172 F.3d 288 (3d Cir. 1999) (explaining proof of conspiracy)
United States v. Gambone, 314 F.3d 163 (3d Cir. 2003) (standard for Rule 29 sufficiency; verdict sustained if substantial evidence exists)
United States v. Flores, 454 F.3d 149 (3d Cir. 2006) (role of court vs. jury in Rule 29 motions)
United States v. Williams, 974 F.3d 320 (3d Cir. 2020) (conspiracy may be proven entirely through circumstantial evidence)
United States v. Caraballo-Rodriguez, 726 F.3d 418 (3d Cir. 2013) (jury verdict must be upheld unless irrational)
United States v. Johnson, 302 F.3d 139 (3d Cir. 2002) (standard for granting Rule 33 new trial)