United States v. Parker, 2017 WL 4129188

On March 2014 Shayne Parker (an African‑American) was indicted for being a felon in possession of ammunition (50 rounds of .38) and for transporting a 9mm SCCY pistol into Massachusetts without a license; a jury convicted and the district court sentenced him to 60 months.
Facts at trial: Parker and Ronald Scott traveled from MA to NH with two straw purchasers (white Riddell and LaMott) who bought multiple firearms in NH; some guns and .38 ammo were later in Boston; drug payment was given to the straw purchasers.
Parker appealed only his convictions, raising three issues: (1) the district court refused individualized voir dire on racial bias, (2) admission of other‑acts (uncharged) gun/ammo purchases, and (3) giving a willful‑blindness jury instruction.
The district court conducted group voir dire including specific race‑bias questions and allowed sidebar follow‑up for jurors who raised hands; the empaneled jury included at least one African‑American.
The court admitted evidence of other straw purchases (March 10, 16, and 22) for intent/knowledge, paired with limiting instructions; Parker objected that this was propensity evidence.
The court gave a willful‑blindness instruction after admitting Parker’s post‑arrest statement (he said he “didn’t want to know” and left when Scott went to get “stuff” meaning guns); Parker argued the instruction was unsupported and relieved the government’s burden.

Issue	Parker's Argument	Government's Argument	Held
Voir dire on racial bias — whether court had to conduct individualized, private questioning	Trial judge abused discretion by refusing individual voir dire despite cross‑racial facts, statistical disparities, and a racially charged atmosphere; jurors won’t admit bias publicly	Group questioning covered race issues and judge reasonably exercised discretion; individual voir dire not required here	Abuse‑of‑discretion review: no reversible error; group questioning plus sidebar follow‑up was sufficient
Admission of other‑acts evidence (uncharged straw purchases)	Evidence was prejudicial propensity evidence used to portray Parker as a bad person and consumed trial time	Evidence was admissible to show knowledge, intent, plan; probative value outweighed unfair prejudice and limiting instructions cured risk	Abuse‑of‑discretion review: admission proper; evidence was similar in time and method and limiting instructions minimized prejudice
Willful‑blindness jury instruction	Instruction inappropriate because no affirmative evidence of deliberate ignorance, it shifted burden and relieved government of proving knowledge	Parker’s post‑arrest statement and trial defense (lack of knowledge) made willful‑blindness proper; instruction was permissive, not mandatory	De novo review: instruction was warranted because defense contested knowledge, evidence supported deliberate ignorance, and instruction did not mandate inference of knowledge

Peña‑Rodriguez v. Colorado, 137 S. Ct. 855 (Sup. Ct. 2017) (constitution may require questions about racial bias to protect impartial jury)
Mu’Min v. Virginia, 500 U.S. 415 (Sup. Ct. 1991) (court need not specify exact form of voir dire or require individual questioning)
United States v. Gelin, 712 F.3d 612 (1st Cir. 2013) (abuse‑of‑discretion standard for voir dire decisions)
United States v. Hosseini, 679 F.3d 544 (7th Cir. 2012) (group voir dire ordinarily sufficient even with potential group‑bias concerns)
Global‑Tech Appliances, Inc. v. SEB S.A., 563 U.S. 754 (Sup. Ct. 2011) (willful blindness is equivalent to knowledge where defendant deliberately avoided learning the truth)
United States v. De La Cruz, 835 F.3d 1 (1st Cir. 2016) (standard of review for willful‑blindness instructions depends on claim’s nature)
United States v. Singh, 222 F.3d 6 (1st Cir. 2000) (willful‑blindness instruction requires defense to contest knowledge and evidence of deliberate ignorance)
United States v. Brandon, 17 F.3d 409 (1st Cir. 1994) (post‑arrest statements showing “didn’t want to know” can support willful‑blindness instruction)