United States v. Colon
United States Court of Appeals for the Seventh Circuit
549 F.3d 565 (2008)
Police wiretaps captured drug supplier Saucedo telling his associate Rodriguez that a buyer, later identified as Colon (defendant), would arrive at a house in 15 minutes to collect previously ordered drugs; officers observed Colon arrive and leave as predicted, then stopped him and found cocaine in his possession. Trial evidence showed Colon had regularly bought distribution-quantity cocaine from Saucedo and Rodriguez on standardized terms over a period of up to six weeks. Colon was convicted of possession with intent to distribute, conspiracy to possess with intent to distribute, and aiding and abetting the conspiracy, and he appealed, arguing the evidence didn't show he was actually part of Saucedo's conspiracy.
Whether repeated drug purchases on standardized terms, without additional evidence connecting the buyer to the seller's broader operation, are sufficient to establish that the buyer participated in the seller's conspiracy.