U.S. v. Garcia

Record contained sufficient evidence to support defendant’s convictions on charges of conspiracy to distribute unlawful drugs and distribution of unlawful drugs, where record showed that defendant provided logistical assistance while another individual sold drugs from secret compartment on empty bus. Ct. of Appeals rejected defendant’s claim that although he may have known that bus contained unspecified contraband, he was unaware that said contraband was unlawful drugs. Dist. Ct. also did not err in denying defendant’s motion for new trial based on contents of four notes that individual jurors gave to Dist. Ct. during trial that suggested that jurors were deliberating on charged offenses prematurely. Record showed that questions pertained to substantive commentary on evidence already admitted, and that Dist. Ct. consistently told jury that it could not comment on said evidence, and that jurors were forbidden from deliberating on charges until close of evidence. While Dist. Ct. and government conceded during trial that jurors’ questions may have suggested that jurors were deliberating during trial, record also suggested possible alternative explanation that jurors were merely confused, and thus there was no overwhelming case of jury’s premature deliberations to support motion for new trial.