United States v. Fitz
United States Court of Appeals for the Eighth Circuit
317 F.3d 878 (2003)
Edwardo Fitz (defendant) traveled with Jose Vega and Jorge Preciado in two vehicles, one of which, the Pathfinder, had drugs hidden in a secret compartment. Preciado met a police informant to discuss the drug sale, then left with Fitz in the other car (the Honda Civic), and both were arrested. At trial, the informant testified he never spoke to Fitz, and there was no evidence Fitz knew about the hidden drugs, had ridden in the Pathfinder, or even understood the English used by Preciado to negotiate the sale with the informant. Fitz was convicted of conspiracy and distribution of methamphetamine and appealed, challenging the sufficiency of the evidence tying him to the conspiracy.
Whether, in a conspiracy prosecution, the government must prove beyond a reasonable doubt that the defendant knowingly entered into an agreement with others for an unlawful purpose.