United States v. San Juanita Medeles-Cab, 754 F.3d 316

Border Patrol intercepted Medeles–Cab at a Laredo checkpoint with ten kilograms of cocaine hidden in a car she drove, along with three of her children.
Medeles–Cab claimed no knowledge of the drugs and testified she was shopping and doing a favor for a friend.
The government adduced on-scene statements, cell-phone communications, and DEA Agent Osborne’s testimony about cocaine economics.
Agent Osborne testified about price differentials and the economics of drug trafficking to explain drug operations, which Medeles–Cab challenged as an improper drug courier profile.
The district court instructed the jury that knowledge of possession need not extend to knowledge of the particular drug involved, Medeles–Cab was convicted on the possession count, acquitted on conspiracy, and sentenced to the statutory minimum.
Medeles–Cab appeals arguing plain-error review applies to the challenged testimony and closing argument, and that knowledge of drug type/quantity is required under § 841 and not proven.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Osborne’s testimony constitutes improper drug courier profile evidence	Medeles–Cab argues it draws a link between paying the driver and knowledge of drugs	United States contends testimony explains drug-trafficking economics, not knowledge	No plain error; testimony is permissible business-model evidence
Whether the prosecutor’s closing argument violated due process or amplified any error	Prosecutor’s remarks rest on improper inference about payment and shopping	Argument was a permissible inference from evidence	No reversible error; comments were supported by evidence and framed as inferences
Whether knowledge of the type and quantity of drugs is an element Medeles–Cab must know under § 841	Knowledge of drug type/quantity is required	Betancourt forecloses requirement of knowledge of type/quantity	Affirmed under Betancourt; knowledge element not required for type/quantity
Whether jury instructions properly stated the knowledge element	Instructions misstate knowledge requirement	Instructions aligned with Betancourt	Affirmed; instruction correct under Betancourt
Whether the evidence supports knowledge beyond reasonable doubt	Evidence shows defendant knowingly transported drugs	Evidence insufficient to prove knowledge of drug specifics	Affirmed; Betancourt governs knowledge standard

United States v. Gonzalez–Rodriguez, 621 F.3d 354 (5th Cir. 2010) (drug courier profile admissibility and its limits; permissible business-model testimony vs. direct knowledge claims)
United States v. Morin, 627 F.3d 985 (5th Cir. 2010) (illustrates permissible vs. impermissible profile testimony; later reversal for plain error in other contexts)
United States v. Gutierrez–Farias, 294 F.3d 657 (5th Cir. 2002) (limits on expert testimony about defendant's knowledge; 403 balancing)
United States v. Williams, 957 F.2d 1238 (5th Cir. 1992) (definition of drug courier profile and limits on its use)
United States v. Betancourt, 586 F.3d 303 (5th Cir. 2009) (knowledge element not required for type/quantity under § 841(a)(1))