Willful Blindness Case Summary

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Pages: 7

The District Court was correct in allowing the governments proposed willful blindness instruction to be read. Willful blindness instructions are appropriate when a judge determines that the “jury could rationally find deliberate ignorance, even if rejecting the government’s evidence of actual knowledge.” United States v. Heredia, 483 F.3d 913, 922 (9th Cir. 2007); See United States v Ramos-Atondo, 732 F.3d 1113, 1118 (9th Cir. 2013). When defendants put forth a defense renouncing their actual knowledge, the government is “entitled to instructions supporting all rational inferences the jury might draw from the evidence.” See Id. (citing Heredia, 483 F.3d at 923). This allows the instruction to be used even if willful blindness is not the governments “case-in-chief.” Id. at 1120. To …show more content…
Poe was well aware of Sonic’s manufacturing. The process involved crushing and synthesizing over the counter drugs before pressing the powder into new pills. R. 26. Appellant described to his customers that he combined two legal substances, and therefore, Sonic was legal, R. 35; however, this is an act commonly undertaken by those attempting to stay ahead of drug laws. While none of these facts are completely analogous to what defendants knew in Ramos-Atondo, they are parallel in that all point to a high probability of dealing with a controlled substance. Based on this knowledge, Appellant took actions, similar in purpose to those in Ramos-Atondo, to conceal his actions. He packaged his pills in non-descript, plain white jewelry boxes. R. 27. Distribution was made outside the normal channels of sale, such as: having no store front, conducting a cash only business, and asking clients to not provide his name. R. 25, 36. Each of these, even though done in the open at a local coffee house, R. 27, where carefully undertaken to ensure that the underlying nature of his business was conducted in