United States v. Takasha Stevenson, 663 F. App'x 831

Stevenson was convicted of conspiracy to commit money laundering under 18 U.S.C. § 1956(h) and appealed.
Evidence at trial: testimony that Stevenson delivered and stored drugs, stored cash proceeds, wired money for drug payments, and received cash transfers into her bank account.
Expert testimony described the pattern of deposits and withdrawals as consistent with movement of drug proceeds; Stevenson knew of a co-defendant’s prior drug convictions and solicited money from him.
Stevenson testified she did not know the money in her account was drug proceeds; jury found her not credible.
At trial, defense counsel declined a proposed definition of “proceeds” when asked by the court; no contemporaneous objection was made to other omitted definitions in the money-laundering instruction.
On appeal Stevenson argued (1) insufficiency of the evidence and (2) plain error in jury instructions for failing to define “proceeds,” “concealment,” and “intent to promote.”

Issue	Plaintiff's Argument (Stevenson)	Defendant's Argument (Government)	Held
Sufficiency of the evidence to convict for conspiracy to launder money	Evidence was insufficient to prove she knowingly joined a laundering scheme	Testimony, bank transfers, expert analysis, and her ties to co-defendant supported a finding she knowingly joined the conspiracy	Affirmed — substantial evidence supported the conviction
Omission of definition of “proceeds” in jury instructions	Omission was erroneous and warranted reversal (relying on Santos)	Defense counsel expressly declined including the definition when offered; invited error doctrine applies	Rejected — invited error bars review; alternatively not plain error
Omission of definitions for “concealment” and “intent to promote”	Failure to define these terms was plain error affecting substantial rights	No controlling Supreme Court authority mandates those definitions; no plain error shown	Rejected — omission was not plain error
Trial judge’s later comment on witness credibility (sentencing)	Alleged that judge’s credibility remark undercuts verdict	Credibility determinations belong to the jury; remarks at sentencing do not undermine jury verdict	Rejected — jury credibility determinations control

United States v. Gregory, 730 F.2d 692 (11th Cir. 1984) (standard for reviewing a motion for judgment of acquittal)
United States v. Edouard, 485 F.3d 1324 (11th Cir. 2007) (de novo sufficiency review, view evidence in government’s favor)
United States v. Azmat, 805 F.3d 1018 (11th Cir. 2015) (agreement and knowledge in conspiracy may be proved circumstantially)
United States v. Martinelli, 454 F.3d 1300 (11th Cir. 2006) (elements of money-laundering conspiracy)
United States v. Brown, 53 F.3d 312 (11th Cir. 1995) (risk when defendant testifies that jury may infer credibility adverse to defendant)
Neder v. United States, 527 U.S. 1 (1999) (timely objection to jury instructions preserves claim; different standard than plain error)
United States v. Santos, 553 U.S. 507 (2008) (plurality and concurring opinions on the meaning of “proceeds” in § 1956)
United States v. Dortch, 696 F.3d 1104 (11th Cir. 2012) (plain-error review for unpreserved jury-instruction objections)
United States v. Felts, 579 F.3d 1341 (11th Cir. 2009) (plain-error standard for unobjected-to jury instructions)
United States v. Fulford, 267 F.3d 1241 (11th Cir. 2001) (invited-error doctrine bars appellate review when defense approves instruction)