The questions presented are whether, in a criminal case, the government may rely on a deliberate ignorance theory of the knowledge mens rea:

(1) to establish a conspiracy, even though a conspiracy conviction requires that a defendant have the mens rea of "purpose," a higher mens rea than knowledge;

(2) when there is no evidence that the defendant took any sort of "deliberate action" to avoid learning (or "knowing") the fact at issue; or

(3) the evidence shows the defendant's "decision" to remain ignorant about the fact at issue was "influenced by coercion?"

Whether the government may rely on a deliberate ignorance theory to establish a conspiracy conviction, when there is no evidence of deliberate action to avoid learning the fact at issue, and the defendant's decision to remain ignorant was influenced by coercion