Harboring18 USC 1071Second Element --
With respect to proving that the defendant had knowledge of the federal
warrant, it is clear that the government may establish such knowledge by
inference. United States v. Gros, 824 F.2d 1487, 1496 (6th Cir.
United States v. Udey, 748 F.2d 1231, 1235-36 (8th Cir. 1984),
denied, 472 U.S. 1017 (1985) ("Direct proof of knowledge of the
a warrant is rarely available. The knowledge element can be established by
evidence from which the jury can properly infer knowledge and guilt beyond a
reasonable doubt."); United States v. Silva, 745 F.2d 840, 848 (4th
1984), cert. denied, 470 U.S. 1031 (1985); United States v.
290 F.2d 83, 84-85 (2d Cir. 1961) (inference of knowledge from the act of
harboring itself). Additionally, it is no defense to a Section 1071
that the defendant was made aware of a warrant that was not actually
at the time, when another outstanding warrant existed. United States v.
Bissonette, 586 F.2d 73, 77 (8th Cir. 1978). However, the knowledge
cannot be satisfied merely by proof that the defendant was "willfully blind"
to the existence of a warrant. United States v. Wyatt, 807 F.2d
1481-82 (9th Cir. 1987); United States v. Hogg, 670 F.2d 1358, 1362