What is the current state of the law on the inference of knowledge by a jury in a criminal case?

MultiRegion, United States of America

The following excerpt is from United States v. Anderson, 747 F.3d 51 (2nd Cir. 2014):

5. The majority also asserts that our sister circuits have adopted similar inferences on records similar to the one here. On close examination, however, in each case there was more extensive evidence presented at trial to warrant such an inference than was presented in this case. See, e.g., United States v. Gbemisola, 225 F.3d 753, 75960 (D.C.Cir.2000) (noting that travel to a distant city, the suspicious manner in which packages were retrieved, use of false names on mailboxes, and defendant's actual removal of contents from the package coupled with the use of the false bottom pots which presented a hazard to an innocent recipient supported an inference of knowledge); United States v. QuilcaCarpio, 118 F.3d 719, 72122 (11th Cir.1997) (holding that, in an airport-smuggling case, a jury may infer knowledge from the high-value nature of cargo in defendant's care, but noting that in this specific case it was reasonable to infer knowledge about the contents of his own luggage given that it was unlikely for a prudent smuggler to entrust high value cargo to an innocent person (especially in that innocent person's own luggage) and it was unlikely defendant was unaware of the contents of his bag given its unusual weight); United States v. UriosteguiEstrada, 86 F.3d 87 (7th Cir.1996) (observing also that the jury could infer knowledge from defendant's possession and control of one million dollars in heroine and suspicious travel history).

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