United States Court of Appeals for the Second Circuit · 2019-04-01
21usc846: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
Role: applied; posture: criminal appeal from conviction for conspiracy to distribute and possess with intent to distribute methamphetamine (21 U.S.C. § 846); sufficiency of conspiracy evidence affirmed; result: claimant-won; claim:
Uncertainty
opinion: IR text is capped at 60000 chars and ends inside the CONCLUSION; any footnotes or separate opinion beyond the cap are not visible
Element agreement: scope: section V announces de novo sufficiency review but its operative sentence is a plain-error ruling on an unrequested buyer-seller instruction; the opening paragraph states that the evidence was sufficient to support all convictions, so the block is kept as a merits sufficiency ruling.
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 8
| Case | Identified offense in Subchapter I | Agreement of two or more persons to the unlawful object | Knowledge of the unlawful agreement and objective | Knowing and voluntary participation in the agreement | Withdrawal before the applicable limitations period | Intent to commit the identified object offense |
|---|---|---|---|---|---|---|
| United States v. Lyle — 919 F.3d 716 (2019) · United States Court of Appeals for the Second Circuit · 2019 (21usc846: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Elements 7–8 of 8
| Case | Conduct beyond preparation strongly corroborating intent | Object-offense penalty incorporation |
|---|---|---|
| United States v. Lyle — 919 F.3d 716 (2019) · United States Court of Appeals for the Second Circuit · 2019 (21usc846: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| United States v. Lyle — 919 F.3d 716 (2019) · United States Court of Appeals for the Second Circuit · 2019 — satisfied · proved (21usc846: author: Flash3 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Agreement of two or more persons to the unlawful object | satisfied Counted merits instance applied / merits basis: proved; party: Michael Van Praagh; count: Count 1 (21 U.S.C. § 846); subject: party=Michael Van Praagh; count=Count 1 (21 U.S.C. § 846) Van Praagh's sufficiency challenge was that he was only Lyle's seller. The court found a conspiracy beyond buyer-seller from his sales to many other customers and from repeated pound-level sales to Lyle, himself a dealer. | buyer-seller-exception/supplier-with-many-customers-repeatedly-sells-pound-quantities-to-a-fellow-dealer | The crux of a conspiracy is an agreement between two or more persons to join together to accomplish something illegal.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [53377:53495] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.Under this exception, "the existence of a buyer-seller relationship does not itself establish a conspiracy; however, where there is additional evidence showing an agreement to join together to accomplish an objective beyond the sale transaction, the evidence may support a finding that the parties intentionally participated in a conspiracy."Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [53905:54247] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.Van Praagh regularly sold methamphetamine to Lyle, who was also a methamphetamine dealer in the New York area.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [1978:2088] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.With assistance from Tarantino, he regularly sold methamphetamine out of his apartment in Queens as well as out of hotels, and he made deliveries to "[p]robably 50" customers.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [55614:55789] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.Tarantino testified that Lyle repeatedly purchased pound-level quantities of methamphetamine at $19,000 to $25,000 per pound.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [55879:56004] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.The district court did not plainly err in failing to give a buyer-seller instruction because the government presented ample evidence of a narcotics conspiracy beyond a buyer-seller relationship between Van Praagh and Lyle.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [55232:55454] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551.Because we conclude that the evidence at trial was sufficient to support all convictions, the challenged searches and seizures did not violate the Fourth Amendment, the admission of Lyle's statements did not violate the Fifth Amendment, and Van Praagh's sentence was reasonable, we affirm the judgments of the district court.Source: docroot/ir/caselaw/f3d_919.jsonl#/f3d/919/0716-01; Unicode character offsets [760:1085] (end exclusive); SHA-256 acf835c61e902d576848d051925e7794aa32249c47a3d3a79e5299e004349551. |