United States v. Rodane Lamb, 704 F. App'x 845

Rodane Lamb was convicted by a jury and sentenced to 144 months for conspiring to distribute 5+ kilograms of cocaine (21 U.S.C. §§ 841(a)(1), (b)(1)(A), 846).
Co‑conspirators testified Lamb partnered with them: buying, packaging, counting cash, splitting proceeds, and shipping money between Florida and California.
Witnesses placed Lamb at activities supporting the drug enterprise, including receiving large mailed sums (one call identified as from Lamb) and sharing an apartment in California to facilitate sales.
Law enforcement recovered 40 kilograms of cocaine; testimony indicated Lamb typically bought 12–15 kilograms and was connected to transports involving that 40‑kg shipment.
Lamb moved for judgment of acquittal on sufficiency grounds; the district court denied the motion. On appeal, Lamb challenged sufficiency of evidence as to (1) existence of a conspiracy and his membership, and (2) the 5+ kilogram quantity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that a conspiracy existed and Lamb was a member	Government: co‑conspirator testimony and postal/money‑transfer evidence showed a partnership and joint activity	Lamb: record insufficient to prove he joined a conspiracy (argument not raised below, reviewed for plain error)	Affirmed — testimony and circumstantial evidence were sufficient; no plain error
Sufficiency of evidence that conspiracy involved 5+ kilograms	Government: co‑conspirator testimony about Lamb buying 12–15 kg, plus recovery of 40 kg tied to associates	Lamb: challenged quantity below reasonable doubt standard	Affirmed — evidence supported a finding of >= 5 kg;

United States v. Jiminez, 564 F.3d 1280 (11th Cir. 2009) (standard for sufficiency review; view evidence in government’s favor)
United States v. Holmes, 814 F.3d 1246 (11th Cir.) (standard for reviewing denial of judgment of acquittal)
United States v. Hunerlach, 197 F.3d 1059 (11th Cir. 1999) (plain‑error review when argument not raised below)
United States v. Green, 40 F.3d 1167 (11th Cir. 1994) (elements required to prove drug conspiracy)
United States v. Guerrero, 935 F.2d 189 (11th Cir. 1991) (government need not prove conspirator knew all details or participated in every phase)
United States v. McDowell, 250 F.3d 1354 (11th Cir. 2001) (common purpose and plan may be inferred from circumstances)
United States v. Turner, 474 F.3d 1265 (11th Cir. 2007) (plain‑error test requires showing of error that is plain and affects substantial rights)