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United States v. Brock

United States Court of Appeals for the Second Circuit
789 F.3d 60 (2015)


The federal government (plaintiff) prosecuted Jayquis Brock, Joseph Jackson, James Dickerson, and 35 others (defendants) for narcotics offenses, in violation of 18 U.S.C. § 841, and for conspiracy to commit such offenses, in violation of 18 U.S.C. § 846. Brock pleaded guilty and agreed to testify as a government witness. The federal district court trial evidence established that Jackson was at the center of a large conspiracy to distribute drugs illegally. Brock, one of Jackson's dealers, sold crack cocaine to 40 customers. Dickerson regularly bought large supplies of crack, not only from Brock, but also from suppliers outside Jackson's network. Brock testified that he had no resale agreement with Dickerson, and that although Dickerson was a good customer, he did not regard Dickerson as his co-conspirator. Dickerson moved for a judgment of acquittal on the conspiracy charge. The judge denied Dickerson's motion, ruling that a reasonable jury could infer that Dickerson's steady demand for, and Brock's steady supply of, wholesale quantities of crack gave each man a conspiratorial stake in the growth of the other man's business. The jury found Dickerson guilty on both counts. Dickerson appealed to the Second Circuit Court of Appeals.

Rule of Law


Holding and Reasoning (Parker, J.)

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