United States v. Jewell
532 F.2d 697 (1976)

  • Jewell crossed the border into the US with a large amount of drugs in a secret compartment in his car.
    • Jewell claimed that it wasn’t his car, and he did not know that there were drugs hidden in it.
      • Jewell did admit knowing that there was a secret compartment, but he willfully chose not to look in it.
  • The Trial Court convicted Jewell of drug possession. He appealed.
    • Jewell argued that without knowledge that there were drugs in the car, he was lacking the mens rea requirement for a conviction.
      • In general, mens rea requires that the defendant intended, expected, or should have expected that their actions would produce a particular consequence.
  • The Appellate Court affirmed.
    • The Appellate Court found that Jewell made a conscious purpose to disregard the nature of that which was in the vehicle, with a conscious purpose to avoid learning the truth.
    • The Court noted that in order to prove willful blindness, the prosecution must prove “beyond a reasonable doubt, that the defendant was not actually aware and that his ignorance in that regard was solely and entirely a result of a conscious purpose to avoid learning the truth.”
      • So, if a defendant can show that they reasonably believed that there were no drugs in the package, then cannot be found guilty. It is only if they go out of there way to avoid learning the truth in an effort to avoid knowledge.
        • In a dissent it was suggested that a someone who gets a wrapped birthday present while on a trip has a conscious purpose to take it home without learning what is inside. But his state of mind is totally innocent unless he is aware with a high probability that the package contains drugs.
  • The Model Penal Code §2.02(7) discusses the concept of willful blindness, where a person purposely doesn’t look because they don’t want to know. In that case, the person still has mens rea, and can be found guilty of a crime because they are acting with reckless disregard.
    • Another way to think of it is that in order to be guilty you have to have acted purposefully to commit a crime. If you are purposefully avoiding the knowledge, you are still acting purposefully.