Copeland v. United States

CourtDistrict of Columbia Court of Appeals
DecidedMarch 17, 2022
Docket20-CM-52
StatusPublished

This text of Copeland v. United States (Copeland v. United States) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Copeland v. United States, (D.C. 2022).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 20-CM-52

LAFFETTE COPELAND, APPELLANT,

V.

UNITED STATES, APPELLEE.

Appeal from the Superior Court of the District of Columbia (CMD-10801-19)

(Hon. Carol Dalton, Motion Judge) (Hon. Robert Okun, Trial Judge)

(Argued October 27, 2021 Decided March 17, 2022)

Adrian Madsen for appellant.

Mark Hobel, Assistant United States Attorney, with whom Michael R. Sherwin, Acting United States Attorney at the time, and Elizabeth Trosman, Suzanne Grealy Curt, and Andy Wang, Assistant United States Attorneys, were on the brief, for appellee.

Before BLACKBURNE-RIGSBY, Chief Judge, GLICKMAN, Associate Judge, and THOMPSON *, Senior Judge. * Senior Judge Thompson was an Associate Judge of the court at the time of argument. On October 4, 2021, she was appointed as a Senior Judge but she continued to serve as an Associate Judge until February 17, 2022. See D.C. Code § 11-1502 & 1504(b)(3) (2012 Repl.). On February 18, 2022, she began her service as a Senior Judge. See D.C. Code § 11-1504. 2

THOMPSON, Senior Judge: Following a bench trial, appellant Laffette

Copeland was found guilty of simple assault. She makes several arguments as to

why she is entitled to relief from her conviction and/or sentence. First, she argues

that the trial court erred in ruling that video footage of the incident was not in the

government’s possession, custody, or control. Second, she asserts that her pretrial

proffers raised an inference that a member of the prosecution team acted in bad

faith in failing to preserve video footage, that the trial court erred in failing to hold

an evidentiary hearing, and that the court further abused its discretion in denying

her motion for dismissal of the charge or other sanction because of the

government’s violation of Rule 16 of the Superior Court Rules of Criminal

Procedure and the Due Process Clause. Third, appellant contends that the trial

court abused its discretion in declining to sentence her under the District of

Columbia Youth Rehabilitation Act (“YRA”). 1 For the reasons discussed below,

we vacate the conviction and the trial court’s denial of appellant’s motion for the

sanction of dismissal and remand for further proceedings.

I.

1 See D.C. Code § 24-903 (2021 Supp.). 3

On August 19, 2019, appellant was charged by information with simple

assault against complainant Natosha Gant-Jones, whom, the government alleged,

appellant struck in the face on August 21, 2018, near a District of Columbia

building located at 441 4th Street, N.W. At appellant’s August 19, 2019,

arraignment — almost a year after the incident — defense counsel provided the

government a copy of the defense’s initial preservation and discovery request,

which included a request for any police department video footage recorded within

a quarter mile of where the incident occurred. On August 31, 2019, defense

counsel sent the government another written discovery request, which specifically

sought, inter alia, video footage from the Protective Services Division (“PSD”) 2

CCTV mounted on the building located at 441 4th Street, N.W. During a

proceeding on September 13, 2019, defense counsel asked in open court that the

government provide or permit the defense to inspect “a copy of the [PSD] video

footage recorded by the camera at the time and location of the alleged incident.” 3

2 PSD is a part of the District of Columbia Department of General Services (DGS), which in turn is a “subordinate agency within the executive branch of the District government.” D.C. Code § 10-551.01 (2019 Repl.). PSD “coordinat[es], manag[es], and provid[es] security services for District government facilities [including 441 4th Street, N.W.] through the use of special police officers and security officers, . . . civilian employees, or contractors.” D.C. Code § 10- 551.02(6) (2019 Repl.). 3 Defense counsel represented to the trial court that the camera “sits directly above th[e] intersection” of 4th and E Streets, N.W. 4

There followed a September 19, 2019, email in which defense counsel again asked

the government for the PSD video footage.

In an e-mail sent on September 25, 2019, government counsel told defense

counsel, “There is no surveillance video to produce. I have been informed by our

head of security that our footage is in 30 day overwrite mode. Given that this

incident happened in August of 2018, no footage would exist now.” Another email

in the record reveals that the advice from the “head of security” referred to in the

September 25, 2019, email actually pertained to surveillance footage from the

United States Attorney’s Office (“USAO”) building located at 555 4th Street,

N.W., which “ha[s] a camera that sees the NW corner of the [Fourth and E Streets]

intersection (provided it was focused f[o]r the distance involved).” The September

25, 2019, email did not specifically address the availability of footage from the

PSD surveillance camera, though the government later represented in its opposition

to appellant’s motion for dismissal as a discovery sanction that “PSD cameras also

operate in 30-day overwrite mode . . . .” The government also stated in its

opposition that government counsel had been informed by “[t]he District Office

Security Manager” of the USAO Building “that he is not aware of any other

camera under federal control that is aimed at the intersection in question.” The

government acknowledged that the Metropolitan Police Department (“MPD”), 5

“during the course of its investigation, did not request that any footage be

preserved.”

On October 14, 2019, “pursuant to Super. Ct. Crim. R. 16 and the Fifth

Amendment,” appellant moved for the trial court to “dismiss the case against her

as a sanction for the government’s failure to preserve District of Columbia [PSD]

footage showing the events leading up to the alleged incident . . . , the alleged

incident itself, and the events following the alleged incident.” The government

opposed the motion, and appellant filed a reply on November 18, 2019, arguing

that because the government “failed to preserve critically important evidence,

dismissal is the appropriate remedy.”

On November 25, 2019, the trial court (the Honorable Carol Ann Dalton)

summarily denied the defense’s motion in a one-page written order. At a hearing

held that same day, Judge Dalton explained her reasoning as follows: “[I]t was a

year after the crime occurred. The case wasn’t brought until a year later. There is . .

. nothing about it being exculpatory. It’s probably at most a black hole, and for

that reason, I denied it.” Asked by defense counsel to clarify her reasoning, Judge

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