United States v. Richard Caraballo-Rodriguez, 2013 U.S. App. LEXIS 16407

Appellee Caraballo-Rodriguez and co-defendant Deya-Diaz were arrested after a May 1, 2008 drug shipment from Puerto Rico to Philadelphia; four suitcases contained nearly 50 kg of cocaine with a $5 million retail value.
Deya-Diaz testified at trial that he was paid to retrieve suitcases but claimed he did not know their contents; later recanted and described an arrangement involving a third party, Domi, paying for the trip.
The government charged conspiracy to distribute cocaine and related offenses; Deya-Diaz pleaded guilty and testified, corroborating some details against Caraballo-Rodriguez and Cordero.
District Court granted acquittal to Caraballo-Rodriguez after trial, finding insufficient evidence that he knew the conspiracy’s object was drugs.
The Third Circuit convened en banc to resolve whether the sufficiency standard in drug-conspiracy cases requires a stricter, non-deferential review or the ordinary deferential standard applicable in other criminal cases.
The court vacated the district court and remanded, adopting a deferential, “bare rationality” standard for sufficiency review and allowing knowledge to be proven by circumstantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
What is the proper standard of review for sufficiency in drug conspiracy cases?	Caraballo-Rodriguez argues the standard should align with strict scrutiny of knowledge.	Caraballo-Rodriguez contends the court should apply a routine Jackson v. Virginia standard with close scrutiny.	Adopt deferential standard; uphold jury verdict if rationally winnable beyond reasonable doubt.
Whether the evidence suffices to show knowledge that the conspiracy’s object was drugs	Government contends the record shows knowledge by grain-by-grain inference from circumstances.	Defense argues lack of specific knowledge tying him to drugs; insufficient direct evidence.	Evidence, viewed totality, supported knowledge beyond a reasonable doubt under the new standard.
Does willful blindness instruction suffice to establish knowledge of the drug conspiracy?	Willful blindness allowed inference that defendant knew the drugs were involved.	No error if evidence fails to show actual knowledge or deliberate ignorance.	Willful blindness instruction proper and consistent with the standard; supports inference of knowledge.
Should the court reweigh evidence or defer to the jury’s inference under the new standard?	Evidence supports the jury’s inference that the object was drugs.	Reweighing is improper; evidence could be consistent with non-drug contraband.	Court reaffirms deference to jury; as long as there is a rational inference, verdict stands.

United States v. Boria, 592 F.3d 476 (3d Cir. 2010) (sufficiency review in drug conspiracies; standard clarified)
United States v. Claxton, 685 F.3d 301 (3d Cir. 2012) (totality-of-the-evidence approach to knowledge of conspiracy subject matter)
United States v. Wexler, 838 F.2d 88 (3d Cir. 1988) (early strict approach requiring evidence of knowledge of drugs)
United States v. Salmon, 944 F.2d 1106 (3d Cir. 1991) (insufficient evidence that defendant knew drugs were involved)
United States v. Idowu, 157 F.3d 266 (3d Cir. 1998) (lack of specific evidence of knowledge of transaction’s subject matter)
United States v. Iafelice, 978 F.2d 92 (3d Cir. 1992) (owner/operator knowledge as an inferential basis for knowing drugs)
United States v. Caminos, 770 F.2d 361 (3d Cir. 1985) (deliberate ignorance inference supported by circumstances)
United States v. Cooper, 567 F.2d 252 (3d Cir. 1977) (pleading and circumstantial evidence sufficient for guilt; threshold of bare rationality)
Jackson v. Virginia, 443 U.S. 307 (Supreme Court 1979) (the rational-trier-of-fact standard for sufficiency of evidence)
Coleman v. Johnson, 132 S. Ct. 2060 (Supreme Court 2012) (bare rationality standard for sufficiency review)