United States v. Robert Little, 961 F.3d 1035

Little, serving a federal sentence at FCI Oxford, was approved for furlough to a CABH halfway house in Rapid City with a prescribed travel schedule and a requirement to call the facility/FCI if anything went wrong.
He signed an "Understanding" acknowledging he remained in custody, was limited to the destination/route, and could be charged with escape for failing to remain within extended limits.
Little departed as scheduled but arrived at CABH on February 8, two days late; heavy winter storms canceled key bus segments, and the earliest available bus arrival was February 8.
The Government proved Little did not arrive on time and presented no evidence he called authorities; the record is silent about how he traveled or whether he had phone access.
A jury convicted Little of escape under 18 U.S.C. §§ 751 and 4082; the district court imposed five months consecutive imprisonment; Little appealed challenging sufficiency of evidence on willfulness.
The Eighth Circuit reversed, holding the Government failed to prove the willfulness element given the bus cancellations and absence of evidence Little had or could access a phone.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Little willfully violated the "extended limits of confinement" (escape element)	Government: failure to arrive and failure to call violated furlough conditions; jury could infer willfulness	Little: impossible to arrive on time by bus; no evidence he had phone access; inability to call negates willfulness	Reversed: Gov failed to prove willfulness; impossible travel and no proof of phone access preclude reasonable inference of willful conduct
Scope of "extended limits of confinement" (physical vs broader conditions)	Government: "limits" may include geographic, temporal, associational, and other restraints; violating any condition can be escape	Little: term refers to physical/geographic boundaries only	Court declined to adopt a broad rule here; assumed, arguendo, failing to call could violate limits but resolved case on lack of willfulness
Effect of jury rejecting necessity defense on Government's burden of proof	Government: jury rejection of necessity supports verdict	Little: even if necessity rejected, Government still must prove every element including willfulness	Held: Rejection of an affirmative defense does not relieve Government of proving each element; burden remains on Government

United States v. Bailey, 444 U.S. 394 (U.S. 1980) (elements of escape offense and mens rea discussion)
Dixon v. United States, 548 U.S. 1 (U.S. 2006) (willfulness in criminal statutes requires knowledge conduct was unlawful)
United States v. Bruguier, 735 F.3d 754 (8th Cir. 2013) (mens rea applies to each element of offense)
United States v. Jain, 93 F.3d 436 (8th Cir. 1996) (interpretation of "willful" in statutory context)
United States v. Chatmon, 742 F.3d 350 (8th Cir. 2014) (standard for reviewing sufficiency of the evidence)
United States v. Serrano-Lopez, 366 F.3d 628 (8th Cir. 2004) (appellate deference to jury verdict but strict sufficiency review)
United States v. Barrera, 628 F.3d 1004 (8th Cir. 2011) (argument is not evidence)