United States v. Jewell

ProfessorScott Caron

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Citation. 130 S. Ct. 3297; 176 L. Ed. 2d 1188;2010 U.S.78 U.S.L.W. 3667

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Citation130 S. Ct. 3297; 176 L. Ed. 2d 1188;2010 U.S.78 U.S.L.W. 3667

Brief Fact Summary. Appellant contends that he did not have the requisite mental state when he drove a car into the United States that contained concealed drugs. Appellant argued that he had no actual knowledge of the drugs.

Synopsis of Rule of Law. Willful blindness is equivalent to knowledge.

Points of Law - Legal Principles in this Case for Law Students.

In determining whether to reassess a sentence or order a rehearing, we consider the totality of the circumstances, including the following illustrative, but not dispositive, factors: (1) dramatic changes in the penalty landscape and exposure, (2) the forum, (3) whether the remaining offenses capture the gravamen of the criminal conduct included within the original offenses, (4) whether significant or aggravating circumstances remain admissible and relevant, and (5) whether the remaining offenses are the type with which we as appellate judges have the experience and familiarity to reliably determine what sentence would have been imposed at trial by the sentencing authority.

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Facts. Appellant entered the United States driving a car with 110 pounds of Marijuana concealed in a hidden compartment. Appellant alleged that he did not know that the car contained drugs and remained ignorant. The State alleged that to convict, the jury must find that Appellant ‘knowingly’ brought the marijuana into the United States and that he ‘knowingly’ possessed the marijuana.

Issue. Whether willful ignorance constituted knowingly under the statute in question.

Held. Affirmed.
One may deliberately shut his eyes to avoid knowing what would otherwise by obvious to view. In such cases, the person acts at his peril and is treated as having knowledge of the facts as ultimately discovered to be.

To act ‘knowingly’ is not necessarily to act only with positive knowledge, but also to act with an awareness of the high probability of the existence of the fact in question.

Dissent. The dissent argued that when a statute requires knowledge as an element of a crime, the substitution of some other state of mind cannot be justified. The dissent found persuasive Appellant’s argument that the instruction essentially required Appellant to check the car for drugs. The dissent argued that a proper jury instruction would define knowingly and not give alternatives to it.

Discussion. The Court ruled that Appellant’s interpretation of knowingly is a calculated effort to avoid the sanctions of the statute while violating its substance. The Court noted that Appellant received money to drive the car over the border from a stranger. Appellant also noticed that the car had a concealed compartment. These facts demonstrated that while Appellant could have not seen the marijuana be loaded into the car, he was in essence trying to remain ignorant but knew that something was wrong. The Court ruled that a defendant could not allege he was ‘deliberately ignorant’ because this mental state with respect to this crime was equally culpable as positive knowledge.

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