United States Third Circuit

Following defendant's conviction for drug conspiracy, the district court's order granting defendant's motion for acquittal and entering a judgment of acquittal is vacated and remanded, where: 1) the appropriate standard to apply in reviewing a sufficiency of the evidence challenge in drug conspiracy cases is that the jury's verdict must be assessed from the perspective of a reasonable juror, and the verdict must be upheld as long as it does not "fall below the threshold of bare rationality;" 2) the knowledge element of the conspiracy need not be proven by direct evidence; and here, 3) the jury's guilty verdict did not fall below the threshold of bare rationality because the jury could have reasonably concluded that defendant knew that he was involved in an illegal venture that involved transporting drugs.

Appellate Information

• Decided 08/08/2013
• Published 08/08/2013

Judges

• RENDELL

Court

• United States Third Circuit

Counsel