Summary
This D.C. Circuit opinion affirms the conviction of Luz Fajardo Campos for conspiracy to distribute cocaine and methamphetamine. The court addresses and rejects the appellant's arguments regarding improper venue under the Constitution and federal statutes, the sufficiency of evidence for a single conspiracy versus multiple conspiracies, and a claim of ineffective assistance of trial counsel. Applying plain error review where applicable, the court finds no constitutional or statutory violation and concludes the evidence sufficiently supported the jury's verdict.
Topics
Practice areas
Questions Presented
- Whether venue in the District of Columbia was proper under Article III and the Sixth Amendment.
- Whether the indictment charged a single conspiracy sufficient for conviction.
- Whether appellant received ineffective assistance of counsel under Strickland.
- Whether the sentencing enhancements and forfeiture order were proper.
Holdings
- Venue in the District of Columbia was proper; appellant's venue challenge fails.
- The evidence was sufficient to support a finding of a single conspiracy; the jury could reasonably find beyond a reasonable doubt that a single conspiracy existed.
- Appellant failed to demonstrate deficient performance or prejudice; the ineffective‑assistance claim fails.
- The sentencing enhancements and the forfeiture order are affirmed; no reversible error was found.
Key quotations
“The court need not decide whether an untimely Rule 12(b)(3) motion is subject to review for plain error without a showing of a good cause.” (at 9–10)
“The jury could reasonably find beyond a reasonable doubt that appellant and the co‑conspirators were involved in a single conspiracy.” (at 9–10)
Factual background
Appellant participated in an international drug trafficking conspiracy that involved importing cocaine and manufacturing methamphetamine. She was arrested in Bogotá, Colombia, and later brought to the United States. Evidence included DEA seizures, BlackBerry messages, emails, and testimony from a confidential source describing her central role.
Procedural history
The district court convicted appellant of conspiracy to distribute cocaine and methamphetamine, sentenced her to 264 months imprisonment, 60 months supervised release, and ordered forfeiture of $18,000,000. Appellant appealed on venue, conspiracy, ineffective assistance, and sentencing grounds.