United States v. Robyn Hamilton, 837 F.3d 859

Robyn Renea Hamilton was convicted by a jury of conspiracy to possess with intent to distribute >50 grams of actual methamphetamine, following a five-day trial; sentenced to the 120‑month mandatory minimum and five years supervised release.
Superseding indictment alleged a single, long‑running conspiracy (Jan 2002–June 2014) led by Eduardo Valenzuela and others; Hamilton was one of nine defendants charged.
Witnesses (including Valenzuela, distributors Javier Rodriguez‑Compean and his relatives, Kailee Davis, and other conspirators) testified about a nationwide distribution network and transactions involving Hamilton’s residence.
Evidence showed Hamilton allowed Davis to use her house as a stash house, kept cash in a safe and drugs in a toolbox, maintained transaction records, handled money, and at times used or was furnished methamphetamine.
Hamilton argued the evidence was insufficient both because (1) it did not prove she knowingly joined Valenzuela’s conspiracy (mere presence/association), and (2) at most she was part of a smaller Davis‑only conspiracy, not the single conspiracy charged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Sufficiency to prove Hamilton knowingly joined the conspiracy	Govt: testimony and corroboration show Hamilton permitted stash use, kept records/safe, handled money, and participated in drug use — sufficient to show knowing contribution	Hamilton: mere presence at transactions and non‑participation in deliveries, so evidence shows only association or user/supplier, not knowing membership	Affirmed — evidence was sufficient for a reasonable jury to find knowing participation (minor role still convictable)
2. Whether Hamilton was part of the single, charged Valenzuela conspiracy or a separate smaller conspiracy	Govt: overlapping personnel, transactions, storage of multi‑pound shipments and proceeds at Hamilton’s house tie her into the larger network	Hamilton: her involvement was limited to a discrete, temporal agreement with Davis; Davis operated before and after Hamilton’s involvement	Affirmed — jury reasonably could find a single, overall conspiracy despite shifting participants; no prejudicial variance shown

United States v. Walker, 818 F.3d 416 (standard for reviewing sufficiency of the evidence)
United States v. Alama, 486 F.3d 1062 (elements of conspiracy offense)
United States v. Askew, 958 F.2d 806 (knowing contribution to a conspiracy requires cooperation beyond mere knowledge)
United States v. Ruiz‑Zarate, 678 F.3d 683 (mere presence insufficient to prove conspiracy membership)
United States v. Nunez, 257 F.3d 758 (evidence types supporting conspiracy membership)
United States v. Tran, 16 F.3d 897 (affirming conviction based on participation and facilitation)
United States v. Lopez, 443 F.3d 1026 (minor role does not preclude conviction)
United States v. Miller, 698 F.3d 699 (conspiracy conviction standards)
United States v. Adams, 401 F.3d 886 (distinguishing user/supplier from conspirator)
United States v. Morales, 113 F.3d 116 (single vs. multiple conspiracies is a jury question)
United States v. Smith, 450 F.3d 856 (single conspiracy may encompass changing participants)
United States v. Edwards, 994 F.2d 417 (multiple groups can still form one overall conspiracy)