Mr. Khojayan appealed his client Jose Zepeda-Ramirez’s conviction for Conspiracy to Distribute and Possession with Intent to Distribute over 1000 kilograms of Marijuana at the Ninth Circuit Court of Appeals. The defendant had been found at a Santa Barbara beach after coming by boat from Mexico to the United States to find better paying work as a welder. There were also about 3500 pounds of marijuana on the boat. However, the marijuana was not his, his fingerprints were not found on any GPS device or the bales of drugs. As well, his phone had no evidence of any drug trafficking on it. He drove the boat aimlessly as the captain slept in an effort to get himself to the United States. The appeal raised the lack of sufficient evidence to convict Mr. Zepeda-Ramirez of the crimes he was charged with because he was merely present without any substantive evidence of his guilt, as required by the law in the Ninth Circuit.