US v. Green: Green and his codefendant, Boyd, were tried together and convicted of a drug conspiracy. Boyd, in addition, was convicted of money laundering. The charges arose from a "family-based, years long" conspiracy to bring drugs from South Florida to the Tidewater area of Virginia. The case against Green and Boyd was made largely on the testimony of other members of the conspiracy who had already pleaded guilty.
Boyd and Green both appealed their convictions, which the Fourth Circuit affirmed. Both of them argued that the district court erred by denying their motions for judgments of acquittal. The court disagreed, holding that there was sufficient evidence to support their various convictions. Boyd raised several addition arguments seeking the reversal of his convictions. First, she argued that the district court should have suppressed $54,000 in cash recovered at Boyd's home during his arrest. The court concluded that the money was discovered in plain view during a lawful protective sweep. Second, Boyd argued that the Government violated Batson by striking all teachers from the jury panel as a proxy for excluding women. The court disagreed, holding that it would not extend Batson beyond strikes that are "intentionally invidiously discriminatory" to those merely "having a discriminatory effect." Third, Boyd argued that the district court erred by not giving her proffered "theory of defense" instruction to the jury. The court disagreed, holding that the essential points of that instruction were covered in other parts of the jury charge. Finally, Boyd argued that the prosecution improperly commented on her counsel's behavior during closing argument. The court disagreed.
Judge Gregory dissented from the court's conclusion that the evidence was sufficient to sustain Boyd's money laundering conviction.