United States v. Ignacio Sanchez-Mata

Ignacio Sanchez-Mata appeals from convictions for conspiracy to possess with intent to distribute narcotics, and possession with intent to distribute narcotics. There is insufficient evidence to connect Sanchez-Mata to the drug conspiracy. Similarly, there is insufficient evidence that Sanchez-Mata had dominion or control over the drugs seized. We reverse both convictions.

Standard of Review

We will uphold a conviction if, viewing the evidence in the light most favorable to the government, any rational trier of fact could have found the defendant guilty beyond a reasonable doubt of each element of the crime charged. United States v. Sharif, 817 F.2d 1375, 1377 (9th Cir.1987) (quoting Jackson v. Virginia, 443 U.S. 307 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979)).

Facts

In January, 1987, Border Patrol Agents discovered four bags of marijuana in the remote Jewel Valley area of southern California. Four sets of footprints were visible. At that time, the agents observed a silver Audi in the area; co-defendant Ta-pia-Salas was driving and co-defendant Sanchez-Ortiz was the only passenger. One agent had observed the car about ten times in the area in the early morning hours during the…