United States v. Rogelio Villarreal-Estebis, 18-41038

Defendant Rogelio Villarreal-Estebis was convicted by a jury of: conspiracy to import cocaine, importation of cocaine, conspiracy to possess with intent to distribute cocaine, and possession with intent to distribute cocaine.
District court sentenced him to concurrent 155-month terms plus five years supervised release; Villarreal-Estebis appealed convictions and sentencing decisions.
Drugs were found in a hidden compartment of a Dodge Journey; Villarreal-Estebis claimed the drugs predated his purchase and were missed on an earlier X-ray.
Government relied on circumstantial evidence (implausibility of defendant’s story, nervousness at secondary inspection, inconsistent statements about purchase) to prove guilty knowledge and participation in the conspiracy.
Trial court excluded evidence that a prior owner (who later was convicted) had a drug conviction; court found its probative value outweighed by risk of confusion.
Sentencing disputes: district court applied a two-level enhancement under U.S.S.G. § 3B1.4 for using minors to avoid detection and denied a two-level mitigating-role adjustment under U.S.S.G. § 3B1.2 (courier/lesser participant).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove knowledge of hidden compartment and conspiracy	Govt: circumstantial evidence (nervousness, inconsistent statements, implausible story) shows guilty knowledge	Villarreal-Estebis: drugs could have been hidden before he bought the car; no proof he knew about the compartment or the agreement	Evidence sufficient; conviction upheld (not a manifest miscarriage of justice)
Exclusion of third party’s later drug conviction	Govt: evidence was prejudicial/confusing and properly excluded under Rule 403	Villarreal-Estebis: exclusion deprived him of right to present a complete defense	Exclusion upheld as within Rule 403 discretion; no constitutional error
§ 3B1.4 enhancement for using minors to avoid detection	Govt: defendant affirmatively involved children by bringing them along when he knew he would transport drugs	Villarreal-Estebis: presence of children does not amount to affirmative use to avoid detection	Enhancement proper; defendant’s act of bringing children was affirmative and supports enhancement
§ 3B1.2 mitigating-role (courier) adjustment	Villarreal-Estebis: he was a low-level courier and less culpable than average participant	Govt: record shows knowledge of conspiracy, responsibility, discretion, and benefit	Denial of mitigating-role adjustment not clearly erroneous; district court’s factual finding stands

United States v. Gil-Cruz, 808 F.3d 274 (5th Cir.) (circumstantial evidence required to prove guilty knowledge when drugs are found in a hidden compartment)
United States v. Lopez-Monzon, 850 F.3d 202 (5th Cir.) (implausible explanations, nervousness, and inconsistent statements support inference of guilty knowledge)
United States v. McIntosh, 280 F.3d 479 (5th Cir.) (standard for overturning conviction when record contains evidence pointing to guilt)
United States v. Reed, 908 F.3d 102 (5th Cir.) (Rule 403 balancing and risk of jury confusion in admitting third-party evidence)
United States v. Ramos, 537 F.3d 439 (5th Cir.) (admission of evidence may be excluded when probative value is outweighed by prejudice/confusion)
United States v. Mata, 624 F.3d 170 (5th Cir.) (interpretation of § 3B1.4; affirmative action required to involve a minor)
United States v. Powell, 732 F.3d 361 (5th Cir.) (mere presence of a minor is insufficient for § 3B1.4 enhancement)
United States v. Torres-Hernandez, 843 F.3d 203 (5th Cir.) (standard of review and factors for § 3B1.2 mitigating-role adjustment)
United States v. Bello-Sanchez, 872 F.3d 260 (5th Cir.) (denial of mitigating-role adjustment where defendant had responsibility and benefit)