United States v. Ruiz
United States Court of Appeals for the Eleventh Circuit
59 F.3d 1151 (1995)
Ana Ruiz (defendant) arranged a meeting at which Angel Santana bought cocaine from an undercover agent, and the government charged her with conspiracy to possess cocaine with intent to distribute. Ruiz testified she believed, based on what Santana told her, that Santana was a government informant and that she was helping law enforcement rather than committing a crime, and she requested a mistake-of-fact jury instruction to clarify the willfulness element. The district court denied the instruction, finding Ruiz's theory was not a legally valid defense, and the jury convicted her.
Whether a defendant who reasonably believed she was cooperating with law enforcement, rather than participating in a drug conspiracy, is entitled to a mistake-of-fact jury instruction addressing whether she had the criminal intent required for conviction.