United States v. Jewell
Citation: 532 F.2d 697 (9th Cir. 1976)
Facts
Gordon Jewell drove a car across the Mexican border into the United States. A secret compartment in the car contained 110 pounds of marijuana. Jewell testified that he knew the compartment existed but deliberately chose not to investigate its contents, inferring that the car’s owner did not want him to know what was inside.
Issue
Whether a defendant who is aware of a high probability that a fact exists but deliberately avoids learning the truth can be said to have “knowingly” possessed a controlled substance within the meaning of the federal drug statute.
Holding
The Ninth Circuit held that deliberate ignorance — consciously avoiding knowledge of a fact — satisfies the “knowingly” element of a criminal statute. A deliberate ignorance instruction was proper.
Rule
Willful blindness (deliberate ignorance) is the legal equivalent of knowledge for purposes of criminal mens rea. A defendant cannot escape criminal liability by deliberately remaining ignorant of facts that would otherwise establish guilt.
Significance
Jewell is the leading case on the willful blindness doctrine, which bridges the gap between knowledge and recklessness in criminal law. It is taught alongside the MPC’s knowledge definition (§ 2.02(7)) and raises important questions about the moral equivalence of deliberate ignorance and actual knowledge.