Aaron Emile McArthur v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedJuly 28, 2020
Docket1793192
StatusPublished

This text of Aaron Emile McArthur v. Commonwealth of Virginia (Aaron Emile McArthur v. Commonwealth of Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Aaron Emile McArthur v. Commonwealth of Virginia, (Va. Ct. App. 2020).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Petty, Malveaux and Athey Argued by teleconference PUBLISHED

AARON EMILE McARTHUR OPINION BY v. Record No. 1793-19-2 JUDGE CLIFFORD L. ATHEY, JR. JULY 28, 2020 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF THE CITY OF RICHMOND Gregory L. Rupe, Judge1

Miriam Airington-Fisher (Airington, Stone & Rockecharlie, PLLC, on briefs), for appellant.

Rosemary V. Bourne, Senior Assistant Attorney General (Mark R. Herring, Attorney General, on brief), for appellee.

Aaron Emile McArthur (“McArthur”) appeals his conviction in the Circuit Court of the

City of Richmond for possession of a firearm by a convicted felon in violation of Code

§ 18.2-308.2. McArthur alleges that the trial court erred by: (1) denying his motion to suppress

the firearm in violation of his Fourth Amendment right against unlawful searches, (2) admitting

into evidence the entirety of his criminal history, (3) denying his motion to strike the evidence,

and (4) denying his motion to set aside the verdict.

I. BACKGROUND

On May 12, 2018, Richmond Police Officer Michael Blaylock (“Officer Blaylock” or

“Blaylock”) initiated a traffic stop on a vehicle McArthur was driving for a defective fog light.

After ascertaining McArthur’s identity, Officer Blaylock asked McArthur if there were any

1 Judge Beverly W. Snukals presided over the March 13, 2019 hearing denying appellant’s motion to suppress which is the subject of this appeal. weapons in the vehicle. McArthur stated that the vehicle was owned by his girlfriend and, as far

as he knew, there were no weapons in her vehicle. McArthur then provided Blaylock with an

identification card, which was passed along to Officer Carrie Griffith (“Officer Griffith” or

“Griffith”).

Officer Griffith returned to the police cruiser with the identification card and obtained

criminal and driving information on McArthur from the mobile computer in the police cruiser.

The information included an alert through the Virginia Department of Corrections that McArthur

was thought to have been a member of the Crips gang during a previous incarceration. While

Griffith was obtaining this information, Blaylock asked McArthur to consent to a search of his

girlfriend’s vehicle due to what Blaylock described as McArthur’s “sketchy” demeanor.

McArthur declined to consent to a search of the vehicle because he did not own the vehicle.

McArthur then called his girlfriend to see if she would consent to a search of her vehicle. During

the entirety of the traffic stop, McArthur made no furtive movements around the cabin of the

vehicle and was polite and cooperative with Blaylock.

When McArthur declined to consent to a search of his girlfriend’s vehicle, Blaylock

instructed McArthur to exit the vehicle so that he could conduct a “protective sweep.” McArthur

immediately complied with Blaylock’s request and exited and stood at the rear of the vehicle.

Upon exiting the vehicle, McArthur began to sweat profusely and nervously stated to his

girlfriend on the phone that “they are locking me up.” Blaylock then searched underneath the

driver’s seat where he found a 9mm handgun hidden from view. After discovering the firearm,

Blaylock instructed Officer Griffith to place McArthur under arrest. Officer Griffith did not

inform Blaylock of McArthur’s alleged past gang affiliation until the search of the vehicle and

arrest had been effectuated.

-2- McArthur subsequently moved to suppress any evidence recovered during the search of

the vehicle. McArthur argued that Blaylock lacked a reasonable articulable suspicion that he

was armed and dangerous when he engaged in the protective sweep of the vehicle. The

Commonwealth defended Blaylock’s protective sweep by arguing, in part, that Blaylock had a

reasonable articulable suspicion based on the imputed knowledge Officer Griffith obtained

concerning McArthur’s alleged prior gang affiliation and incarceration. The trial court denied

the motion to suppress, stating, “[t]he factors that the Court relied on are the evasiveness of the

defendant at the scene, the gang affiliation information from [the databases], the high crime area,

the lack of cooperativeness, and all the other conduct the officer testified to and was reflected on

the body cam.”

At trial, McArthur moved to strike the Commonwealth’s case at the conclusion of their

case-in-chief and at the conclusion of all the evidence based, in part, upon the trial court’s failure

to suppress the admission into evidence of the firearm. McArthur was subsequently found guilty

of possession of a firearm as a violent felon and moved to set aside the verdict as contrary to the

law and the evidence. The trial court denied the motion to set aside the verdict before sentencing

McArthur to five years’ incarceration. This appeal followed.

II. ANALYSIS

A. MOTION TO SUPPRESS

On appeal, when considering a challenge to the denial of a motion to suppress, the Court

will review the decision de novo “when the defendant claims that the evidence sought to be

suppressed was seized in violation of the Fourth Amendment.” Glenn v. Commonwealth, 275

Va. 123, 130 (2008). However, we are “bound by the [trial] court’s findings of historical fact

unless ‘plainly wrong’ or without evidence to support them” and “give due weight to the

inferences drawn from those facts by resident judges and local law enforcement officers.”

-3- McGee v. Commonwealth, 25 Va. App. 193, 198 (1997) (en banc). We also view the evidence

in the light most favorable to the prevailing party, the Commonwealth, with all inferences fairly

deducible from that evidence accorded to the Commonwealth. Hill v. Commonwealth, 297 Va.

804, 808 (2019).

1. REASONABLE ARTICULABLE SUSPICION

The Fourth Amendment to the United States Constitution protects individuals from

unreasonable warrantless searches and seizures. In Terry v. Ohio, 392 U.S. 1 (1968), the United

States Supreme Court permitted “a protective search for weapons in the absence of probable

cause to arrest . . . when a [police officer] possesses an articulable suspicion that an individual is

armed and dangerous.” Michigan v. Long, 463 U.S. 1032, 1034 (1983). “Recognizing the

inordinate risk confronting the officer as he approaches a person seated in an automobile, the

Court has extended such protective searches beyond the person, including areas of the passenger

compartment of an automobile in which a weapon may be placed or hidden.” Id.

Whether reasonable suspicion exists is “based on an assessment of the totality of the

circumstances,” Harris v. Commonwealth, 276 Va. 689, 695 (2008), which “allows officers to

draw on their own experience and specialized training to make inferences from and deductions

about the cumulative information available to them that might well elude an untrained person,”

Branham v. Commonwealth, 283 Va. 273, 280 (2012) (citations omitted). Additionally, if it is

reasonable for the officer to suspect that the stopped individual may be armed and presently

dangerous to the officer, “a limited protective search” of the individual being detained is

reasonable under the Fourth Amendment. Adams v.

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