## Facts

- Federal investigators uncovered a large-scale conspiracy to move millions of dollars in narcotics proceeds from the United States to Colombian drug suppliers through staged cash deliveries to an undercover officer posing as a professional money launderer.
- Co-conspirators used a Jeep Cherokee registered to Juan Manuel Huezo to facilitate deliveries and meetings connected to a planned $1 million transfer in two $500,000 installments.
- On November 8, 2004, Huezo drove a co-conspirator to Manhattan; the undercover officer retrieved a black bag containing $500,000 in bundled cash from the Jeep’s trunk.
- On November 9, 2004, Huezo again drove the Jeep for a second arranged delivery; law enforcement stopped the vehicle and found a suitcase containing about $500,000 in cash.
- Huezo did not attend key planning meetings or negotiate laundering terms; the government’s proof of Huezo’s knowledge and intent was circumstantial, relying on his repeated transport role, the extraordinary sums, the secretive methods, and the packaging typical of narcotics proceeds.

## Issues

1. Whether, viewing the evidence in the light most favorable to the government, a rational jury could find beyond a reasonable doubt that Huezo knew the cash was proceeds of specified unlawful activity and intended to participate in a money-laundering conspiracy, satisfying 18 U.S.C. §§ 1956(a)(1)(B)(i) and 1956(h).
2. Whether the district court misapplied Federal Rule of Criminal Procedure 29 by reweighing evidence and rejecting permissible inferences rather than applying the deferential sufficiency-of-the-evidence standard.

## Decision

- The court of appeals reversed the district court’s post-verdict judgment of acquittal.
- The court held the evidence, though circumstantial on mental state, was sufficient for a rational jury to find knowledge and specific intent for both the substantive money-laundering count and the money-laundering conspiracy count.
- The court reinstated the jury’s guilty verdicts and remanded for further proceedings.

## Legal Principles

- A Rule 29 judgment of acquittal is proper only if, after viewing the evidence in the light most favorable to the government and drawing all reasonable inferences in its favor, no rational trier of fact could find the essential elements beyond a reasonable doubt.
- Knowledge and intent for money laundering and related conspiracies may be proven through circumstantial evidence; direct evidence that the defendant was expressly told the funds were illicit or that the defendant explicitly agreed to “launder” money is not required.
- In assessing sufficiency, courts must consider the evidence as a whole and may not disaggregate proof or dismiss reasonable jury inferences as speculative when the circumstances support them (e.g., repeated trusted participation in secretive transfers of unusually large, bundled cash).

## Conclusion

The court held that Huezo’s repeated use of his own vehicle to transport two separate $500,000 cash deliveries under secretive conditions permitted a rational jury to infer that he knew the money was illicit proceeds and that he intended to further a money-laundering scheme, requiring reversal of the district court’s Rule 29 acquittal and reinstatement of the guilty verdicts.


United States v. Huezo, 546 F.3d 174 (2d Cir. 2008)