United States v. Campos
United States Court of Appeals for the Eighth Circuit
306 F. 3d 577 (2002)
Police found 50.6 grams of methamphetamine (well beyond a typical 3.5-gram personal-use amount and worth $1,000-1,500) in Erick Campos's (defendant's) room, along with a gun, ammunition, and false identification, though officers testified he showed no signs of drug addiction and had no drug paraphernalia on his person; a methamphetamine-tainted pen casing was found downstairs, and Campos testified he was an addict who bought the large quantity at a bargain $200 price for personal use, with a defense witness confirming he saw Campos arrange doses for ingestion (though never actually saw him ingest the drug). A jury convicted Campos, but the district judge, crediting the addiction testimony, granted a new trial finding the circumstantial evidence too weak to prove distribution intent beyond a reasonable doubt, and the government appealed.
Whether a district court may grant a new trial by substituting its own assessment of a defendant's credible-seeming personal-use testimony for the jury's reasonable reliance on circumstantial evidence of distribution intent.