United States v. Garcia-Rodriguez.
No. 22-6194. 2/21/2024. W.D.Okla. Judge Bacharach. Fourth Amendment—Plain View—Summary Judgment—Collateral Order Doctrine.
February 21, 2024
Garcia and Garcia-Rodriguez lived in California. They had been a couple and had three children together. Garcia apparently agreed to transport methamphetamine from California to Oklahoma, and he had planned to take Garcia-Rodriguez’s brother on the trip and had arranged to pay him. At the last minute, Garcia told the brother that the trip was canceled. Garcia then invited Garcia-Rodriguez to accompany him, and she accepted. Police stopped Garcia in Oklahoma for traffic violations. The stop led officers to search the car, where they eventually found a bag of methamphetamine hidden inside the rear fender well, two bundles of methamphetamine hidden in the panels for the rear passenger-side door, and 11 bundles of methamphetamine hidden in the panels for the rear door on the driver’s side. The methamphetamine weighed about 29 pounds and had a wholesale value of about $75,000. Garcia-Rodriguez appeared increasingly nervous throughout the traffic stop, and a small amount of methamphetamine was found hidden inside her bra. Garcia-Rodriguez was charged with conspiracy to possess methamphetamine with the intent to distribute and interstate travel in aid of a drug-trafficking enterprise. Garcia-Rodriguez moved for a judgment of acquittal at the close of the prosecution’s case. The district court denied the motion, and a jury found her guilty as charged.
On appeal, Garcia-Rodriguez argued that there was insufficient evidence to show that she was guilty. To convict on both charges, the prosecution needed to prove that Garcia-Rodriguez knew about the methamphetamine hidden in the car. Here, there was no evidence that Garcia had told Garcia-Rodriguez about the methamphetamine or that she had detected the secret compartments, nor do Garcia’s text messages to Garcia-Rodriguez about the trip show that she knew the road trip’s purpose. And while a jury can often assume that someone wouldn’t plant expensive drugs in a car without informing the occupants, such assumption has only applied where other evidence suggested that the occupant had known about the secret compartment. Further, while the government argued that Garcia-Rodriguez might have recognized that the car’s rear doors were modified because the rear door on the driver’s side could not open and the rear door panel on the passenger side was so loose that it came off when a police officer opened the door, this assertion is speculative because the government presented no evidence that Garcia-Rodriguez had tried to open either of the rear doors or that the doors looked suspicious. Lastly, while Garcia-Rodriguez was nervous when questioned, she was over 1,000 miles from home with methamphetamine hidden in her bra and may have suspected that Garcia was involved in some criminal scheme, so her nervousness didn’t constitute evidence that she knew about the secret compartments filled with methamphetamine. Without evidence of Garcia-Rodriguez’s knowledge, the jury could only speculate on whether Garcia-Rodriguez knew about the secret compartments of methamphetamine, and a reasonable jury could not find her guilty of the crimes charged.
The convictions were reversed and the case was remanded with instructions to enter a judgment of acquittal.