United States v. Robert Wayne Cameron
484 F.2d 939, 1973 U.S. App. LEXIS 7830 (1973)
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Rule of Law:
Circumstantial evidence, including the poor quality of a counterfeit note, the defendant's association with a companion engaged in similar acts, and other suspicious behavior, can be sufficient for a jury to infer that the defendant possessed the requisite knowledge that a bill was counterfeit when passing it.
Facts:
- On September 24, 1971, Cameron, accompanied by Barbara Sue Cowgar, went to a gas station to pick up a repaired tire.
- Cameron paid the $2.00 charge with a twenty-dollar bill that the gas station attendant, Roland Farabee, noted 'looked funny' and was of poor quality.
- Earlier that same day, Cowgar had, on three separate occasions, passed counterfeit twenty-dollar bills while she was alone and driving a different car.
- Subsequent to the gas station incident, Cameron accompanied Cowgar to a general store where she passed another counterfeit twenty-dollar bill to get change for a soda machine.
- A witness at the general store, Marilyn Mills, testified it was 'funny' they asked for change because she heard what sounded like coins rattling in Cameron's pocket.
- Cameron testified he was unaware the bill was counterfeit, that Cowgar had given it to him to pay for the tire, and that he had returned the $18.00 in change to her.
- Cameron also admitted to having been present during a conversation about dealing in counterfeit money two or three weeks prior to his arrest.
Procedural Posture:
- Cameron was charged in U.S. District Court with one count of passing a counterfeit federal reserve note.
- A jury trial was held, during which the government introduced evidence of similar acts committed by Cameron's associate.
- At the close of the evidence, Cameron's counsel made a motion for a judgment of acquittal, arguing the evidence was insufficient to prove he knew the bill was counterfeit.
- The district court denied the motion for acquittal.
- The jury returned a verdict of guilty.
- Cameron appealed the district court's denial of his motion to the U.S. Court of Appeals.
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Issue:
Is the circumstantial evidence sufficient for a jury to reasonably conclude that a defendant knew a Federal Reserve note was counterfeit at the time he passed it, in violation of 18 U.S.C. § 472?
Opinions:
Majority - William M. Byrne
Yes. The evidence was sufficient for the jurors to reasonably conclude that Cameron had the requisite guilty knowledge. The court's role when reviewing a denial of a motion for acquittal is to determine whether the evidence is sufficient for jurors to reasonably arrive at a conclusion of guilt. In this case, the totality of the circumstantial evidence, including the poor quality of the bill and the defendant's activities with his companion on the day of the offense, was sufficient to support both the district court's ruling and the jury’s verdict.
Analysis:
This case reaffirms the principle that a defendant's knowledge or 'scienter,' a critical element in many criminal statutes, can be proven entirely through circumstantial evidence. It demonstrates that the prosecution can build a compelling case for a defendant's state of mind by linking them to the related criminal acts of associates and by highlighting suspicious circumstances surrounding the charged offense. The ruling reinforces the high degree of deference appellate courts give to jury verdicts, making it difficult to overturn a conviction on the basis of insufficient evidence so long as a rational jury could have drawn an inference of guilt from the evidence presented.
