Parker v. United States

CourtDistrict of Columbia Court of Appeals
DecidedAugust 14, 2025
Docket23-CO-0080
StatusPublished

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Parker v. United States, (D.C. 2025).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 23-CO-0080

TIMOTHY J. PARKER, APPELLANT,

V.

UNITED STATES, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2010-CF2-012342)

(Hon. Laura A. Cordero, Motions Judge)

(Argued April 10, 2024 Decided August 14, 2025)

Peter A. Bruland, with whom Carter G. Phillips, Jeffrey T. Green, Cody M. Akins, and Alexandra T. Mushka were on the brief, for appellant.

David P. Saybolt, Assistant United States Attorney, with whom Matthew M. Graves, United States Attorney at the time of argument, Chrisellen R. Kolb, Nicholas P. Coleman, and Laura Bach, Assistant United States Attorneys, were on the brief, for appellee.

Before BECKWITH and HOWARD, Associate Judges, and STEADMAN, Senior Judge.

STEADMAN, Senior Judge: Appellant Timothy J. Parker asks us to vacate his

conviction for voluntary manslaughter following his involvement in a shoot-out

between two rival gangs and a resulting death. In his collateral attack to this

conviction under D.C. Code § 23-110, he asserts that during his trial the jury was 2

improperly instructed on an “urban gun battle” theory under Roy v. United States,

871 A.2d 498 (D.C. 2005). We overruled Roy in Fleming v. United States, 224

A.3d 213 (D.C. 2020) (en banc), replacing its “substantial factor” test for proving

causation with a “but-for” test. While acknowledging the error, the government

contends that given its evidence at trial, this misinstruction did not affect the

outcome of the trial. As part of this argument, the government asserts that we must

review what it terms factual findings underlying the trial court’s order denying

Parker’s motion for clear error. We disagree with the government on both issues

and vacate Parker’s convictions for voluntary manslaughter while armed and the

related possession of a firearm during a crime of violence.

I. Factual and Procedural Background

Parker was implicated as a participant in a gun battle between two rival

gangs known as the “Avenue” and the “Circle” that took place on May 30, 2010, in

the Benning Terrace housing complex. 1 The evidence at trial showed that on May

30, three members of the Circle crossed over into Avenue territory and fired

several rounds before returning to the Circle. Soon after, three Avenue members

crossed into the cul-de-sac that marked the Circle’s territory and the two groups

1 The complex consists of “apartment buildings, row houses, and common areas” in the Southeast corner of the District. See McCray v. United States, 133 A.3d 205, 211 n.5 (D.C. 2016). 3

fired upon each other while neighbors ran for cover. In the shooting, Antwan

Buckner, a bystander, was killed when he ran across the courtyard. We have

previously laid out in extensive detail the facts pertaining to the May 30, 2010,

shootout between the Circle and Avenue gangs. See McCray, 133 A.3d at 212-17.

For the purposes of this opinion, we adopt that recitation and limit this opinion to

Parker’s involvement.

A. The Government’s Case at Trial

The trial extended over two months, involving some sixty witnesses and

more than 500 exhibits. Parker was a defendant alongside four Circle

codefendants on six criminal counts: second-degree murder while armed,

conspiracy to commit murder, conspiracy to commit assault, possession of a

firearm during a crime of violence, carrying a pistol without a license, and

unlawful possession of a firearm. In pursuit of second-degree murder while armed,

the government relied on an “urban gun battle” theory to prove that Parker was, by

participating in a gang shootout that led to the death of his best friend, Antwan

Buckner, a “substantial factor” in that death. As it related to Parker, the

government introduced a range of evidence to prove his involvement in the battle,

primarily testimony from an uninvolved resident, Shunedia “Nita” Rajah, that

Parker was armed and was, to her memory, the first person who fired a shot that 4

day. According to Rajah, after Parker fired his first shot, he went back inside to fix

a firearm jam. However, other government witnesses contradicted this testimony

in part and claimed either that Avenue members shot first or that the two groups

began firing at each other at the same time. The government also introduced

testimony from a thoroughly impeached witness who was not present at the

shootout, Kurtis “Kurdo” Faison. According to Faison, Parker confessed to him

while they were in prison that he was one of the masterminds behind the firefight

who had ordered the three Circle members to go over to Avenue territory to initiate

the battle.

In its opening statement, however, the government emphasized to the jury

that the specific details of the battle did not matter, as “under the law, when you go

out there and you just start willy-nilly firing in a public space and turn it into a

battleground, you’re responsible.” In its closing statement after summarizing its

evidence against the codefendants, the government pointedly reoriented the jury,

stating, “[n]ow all of this brings us to a very important question. Just who shot

Antwan Buckner. And the answer is it doesn’t matter.” According to the

government, as each participant “engage[d] in a gun battle with another crew” that

resulted in a death, they all were substantial factors of that death and thus

criminally responsible. 5

Following the two-month-long trial, Parker was acquitted of second-degree

murder while armed but convicted of the lesser-included offense of voluntary

manslaughter while armed, as well as each of the firearms-related charges,

including possession of a firearm during a crime of violence. He also was

acquitted of conspiracy to commit murder, and the trial court declared a mistrial

following a further week of deliberation on the conspiracy to commit assault

charge.

B. Procedural History

During the course of Parker’s direct appeal, this court substantially curtailed

the urban gun battle theory in Fleming, 224 A.3d at 213, as noted above. Parker

attempted to raise a Fleming challenge to his voluntary manslaughter conviction,

but we declined to consider the claim. We said that the proper mechanism for

challenging the alleged instructional error would be to file a motion pursuant to

D.C. Code § 23-110. Parker v. United States, 254 A.3d 1138, 1142, 1147 (D.C.

2021). 2

2 Parker’s conviction was initially affirmed in part and reversed in part with a case remand to the trial court on specific issues. McCray, 133 A.3d at 240. Parker appealed the trial court’s decision following the remand. While this second appeal was pending, we decided Fleming, whereupon Parker raised a Fleming challenge for the first time. Parker, 254 A.3d at 1141. Since the remand from the 6

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