United States v. Garcia

Police arrested truck drivers Juan Garcia (defendant) and Wilfredo Torres after finding 260 pounds of marijuana in their semitruck. Garcia’s truck was in repair, and his trucking company assigned him to join Torres in Torres’s truck. Before the assignment, Torres and Garcia were not friends and had only spoken a few times at work. Torres confessed and repeatedly stated that Garcia had no connection to the drugs. Torres refused to disclose his drug source, and when Torres pleaded guilty, Torres did not implicate anyone else. Before trial, the government (plaintiff) moved to suppress Torres’s statements about Garcia. The parties disputed whether corroborating circumstances clearly indicated the trustworthiness of Torres’s statements. The government argued that some inconsistencies in Torres’s confession regarding Torres’s source and the purchase price of the marijuana implied that Torres was protecting his drug source and was probably protecting Garcia as well. The government also emphasized Torres’s statement that Garcia had to know that something was wrong because suitcases full of marijuana were in the truck’s sleeping area. The federal district court granted the government’s suppression motion. The jury learned that Torres had confessed and pleaded guilty, but the jury did not know that Torres had exculpated Garcia. The government’s trial theory was that Garcia must have known that the trailer was empty and that Garcia must have smelled marijuana in the truck’s sleeping area. A federal jury convicted Garcia of possession with intent to distribute over 100 kilograms of marijuana. Garcia appealed.