APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO. Hon. Francisco A. Besosa, U.S. District Judge.
Michael R. Hasse, for Jose L. Rodríguez-Martinez, appellant. Victoria M. Bonilla-Argudo, for Joel Santini-Mendez, appellant.
Rosa Emilia Rodríguez-Velez, United States Attorney, with whom Nelson Pérez-Sosa, Assistant United States Attorney, Chief, Appellate Division, and Tiffany V. Monrose, Assistant United States Attorney, were on brief for appellee.
Before Howard, Lipez, and Barron, Circuit Judges.
LIPEZ, Circuit Judge.
Appellants Jose Luis Rodríguez-Martinez (" Rodríguez" ) and Joel Santini-Mendez (" Santini" ) were sentenced in the United States District Court of Puerto Rico to terms of eighty-eight months and seventy months, respectively, for aiding and abetting the attempted possession of narcotics with intent to distribute in violation of 21 U.S.C. § 841, and aiding and abetting the possession of a firearm in furtherance of a drug-trafficking crime in violation of 18 U.S.C. § 924(c). Separately, Rodríguez pled guilty to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g)(1).
On appeal, each defendant challenges the sufficiency of the evidence to support certain convictions. Rodríguez claims that there was insufficient evidence for the jury to conclude that he aided and abetted Santini's attempted possession of narcotics (and, as a result, that his possession of a firearm was not in furtherance of that crime). Santini, by contrast, claims there was insufficient evidence to show he possessed a firearm in furtherance of a drug-trafficking crime.
We agree that the government failed to produce sufficient evidence from which a rational jury could conclude that there was a relationship between the respective contraband possessed by Santini and Rodríguez, and we thus reverse those challenged convictions. Having concluded that we must reverse those convictions, we do not reach the other trial and sentencing errors that the defendants raise.
A. Factual Background
We recite the facts as the jury could have found them, viewing the evidence in the light most favorable to the jury verdict. See United States v. Beltran, 503 F.3d 1, 2 (1st Cir. 2007). On August 10, 2012 two police officers, Edwin Morales-Sanchez (" Morales" ) and Orlando Abreu of the Carolina Puerto Rico Police Department Traffic Patrol, conducted a traffic stop at the intersection of Puerto Rico Roads 181 and 852. Morales had spotted a 2002 Honda Accord as it was leaving a parking lot from a hardware store with tinted windows that he suspected were in violation of Puerto Rico traffic law. Santini
was in the driver's seat of the car, and Rodríguez was in the ...