United States of America v. Dustin Moss

2018 DNH 158
CourtDistrict Court, D. New Hampshire
DecidedAugust 2, 2018
Docket17-cr-79-JL
StatusPublished

This text of 2018 DNH 158 (United States of America v. Dustin Moss) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States of America v. Dustin Moss, 2018 DNH 158 (D.N.H. 2018).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Civil No. 17-cr-79-JL Opinion No. 2018 DNH 158 Dustin Moss

MEMORANDUM ORDER

In advance of a trial on a series of charges related to,

among other things, drug trafficking, money laundering, and

witness tampering, defendant Dustin Moss moved to suppress

approximately 20 pounds of methamphetamine discovered in two

Priority Express Mail packages, and any evidence resulting from

the searches of those two packages. This motion turns on

whether Moss had a reasonable expectation of privacy in the

packages, neither of which was addressed to him; whether the

warrant to search one of the packages sufficiently described the

property to be searched; and whether the warrantless search of

the second package fell under the consent and private search

exceptions to the warrant requirement.

After an evidentiary hearing and permitting Moss to

supplement his arguments, the court denied Moss’s motion.1 Moss

then pleaded guilty to one count of attempting to possess with

1 See Order of April 20, 2018. intent to distribute 500 grams or more of a mixture containing

methamphetamine in violation of 21 U.S.C. §§ 846 and

841(b)(l)(A)(viii) and one count of possession of a firearm in

furtherance of a drug trafficking crime in violation of 18

U.S.C. § 924(c).2 Though he waived his right to appeal several

aspects of his plea, Moss, with the government’s consent,

“expressly reserve[d] the right to appeal the denial of his

Motion to Suppress.”3 See Fed. R. Crim. P. 11(a)(2).

This order sets forth the bases for the court’s denial of

Moss’s motion in greater detail. See, e.g., United States v.

Joubert, 980 F. Supp. 2d 53, 55 n.1 (D.N.H. 2014), aff'd, 778

F.3d 247 (1st Cir. 2015) (citing In re Mosley, 494 F.3d 1320,

1328 (11th Cir. 2007)) (noting a district court’s authority to

later reduce its prior oral findings and rulings to writing).

First, the court addresses whether Moss had a privacy interest

in the two packages, neither of which was addressed to him,

sufficient to confer on him standing to challenge the searches

of those packages. It then concludes that, even assuming that

he has standing, neither search violated the warrant

requirements of the Fourth Amendment so as to require

suppression of the evidence obtained through them.

2 Plea Agreement (doc. no. 63) at 1. 3 Id. at 13.

2 Background

The court makes the following findings of fact based on the

testimony and other evidence received at the suppression

hearings.

A. The 730 package

A package bearing the tracking number EL810533730US (the

“730 package”) was mailed from Las Vegas, Nevada, on April 18,

2017. Weighing a little over 26 pounds, it was addressed to a

recipient named O’Rourke at 3 Blackberry Way, apt. 108, in

Manchester, New Hampshire. It bore a return address of “Tom

fairbanks, 328 Florrie Ave.” in Las Vegas.

1. Search of the 730 package

On the evening of April 18, United States Postal Inspector

Bruce Sweet reviewed a list of packages scheduled to arrive in

New Hampshire from Las Vegas, Nevada. Based on his

participation in an investigation into Moss and his co-

defendant, Katrina Jones, between October 2016 and April 2017,

Inspector Sweet was aware of a drug conspiracy wherein packages

from Las Vegas containing methamphetamine arrived in New

Hampshire, and packages containing cash were sent from New

Hampshire to Las Vegas. Some of those packages had “Florrie

Ave.” as a return address. Accordingly, while the package was

still in Las Vegas, Inspector Sweet noticed the 730 package as

3 originating from that street and identified it as suspicious

based on his knowledge of that investigation, the origin and

destination, and its weight.

When the package arrived in Manchester the next morning, he

collected the 730 package and placed it into a package lineup

for a drug-sniffing dog. After the dog alerted on the 730

package, Inspector Sweet secured it in the United States Postal

Inspection Service’s offices.

Working with Assistant United States Attorney William

Morse, Sweet applied for a warrant to search the package. His

affidavit attached to the warrant application correctly and

accurately described the 730 package in “Attachment A” as a

“black ‘Kicker Speaker’ cardboard box,” with its dimensions and

address.4

Having reviewed those materials, the magistrate judge

issued a search warrant that same morning. The warrant’s

caption correctly identified the package, reading: “In the

Matter of the Search of USPS Priority Mail Express Package

Bearing Tracking Number EL810533730US.”5 In its body, the

warrant described the area to be searched as “See Attachment A,

as attached hereto and incorporated herein.” But, due to a

4 Mot. to Supp. Ex. A (doc. no. 52-2) at 7. 5 Mot. to Supp. Ex. B (doc. no. 52-3).

4 clerical error in the United States Attorney’s Office,

“Attachment A” to the issued warrant identified the property to

be searched as a completely different package.6 Inspector Sweet

did not review the warrant or its attachments after it issued or

notice the erroneous “Attachment A” when he executed the

warrant, ultimately served it on O’Rourke, or returned it.

An hour or so after the warrant issued, Sweet searched the

730 package. Inside the box he found a large speaker and,

inside the speaker, 12 zip-top bags, each containing almost

exactly one pound of a white crystalline substance that tests

later identified as methamphetamine. Having replaced the

narcotics with miscellaneous items to bring the box to its

original weight, he repackaged the speaker, resealed the

package, and delivered it to the post office.

2. Delivery of the 730 package

Sabrina Moss, the defendant’s sister and O’Rourke’s dealer,

had asked O’Rourke earlier in April to receive a package on

behalf of her brother. In exchange, she offered him three-and-

6 Id. at 3. The package described in the warrant’s Attachment A is a USPS Priority Mail Express package of a different color (white), size (envelope), and weight (5 ounces), addressed to a different recipient (Mr. Golden) in a different city (Laconia, New Hampshire) from a different sender (Sequoia High School) in a different state (California), and, of course, bears a different tracking number (EL576175385US). Inspector Sweet testified that the package actually described in the warrant’s Attachment A related to a package he searched in November 2016.

5 a-half grams of crack cocaine, which O’Rourke testified he would

value at approximately $300. O’Rourke agreed. Sabrina did not

tell him when the package would arrive or to expect more than

one package. Neither Sabrina nor Moss instructed him either to

open or not to open the package.

After Inspector Sweet concluded his search of the package,

a postal inspector dressed as a letter carrier delivered a

notice to O’Rourke’s mailbox that the package had arrived at the

post office. Several hours later, Moss met O’Rourke at

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2018 DNH 158, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-dustin-moss-nhd-2018.