United States v. Eiland

The government (plaintiff) prosecuted Gerald Eiland and Frederick Miller (defendants) for running a continuing criminal enterprise (CCE) under 21 U.S.C. Section 848, which requires proof the defendant organized or supervised five or more people in the drug operation. Evidence showed Miller directed the Thomas brothers, Charles Brown, and Darius Ames in various drug-trafficking tasks. The evidence connecting Miller to a fifth participant, Jay Ingram, was thinner: agents overheard Miller say he knew Ingram's location and saw the two meet once outside a restaurant. The jury convicted Miller on the CCE counts tied to the Thomases, Brown, and Ames but acquitted him on a separate count involving Ingram, while still finding he supervised Ingram. Miller appealed to the D.C. Circuit.