United States v. Brown

676 F. Supp. 2d 220, 2009 U.S. Dist. LEXIS 119482, 2009 WL 5102844
CourtDistrict Court, S.D. New York
DecidedDecember 18, 2009
Docket09 CR 168(CM)
StatusPublished
Cited by1 cases

This text of 676 F. Supp. 2d 220 (United States v. Brown) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Brown, 676 F. Supp. 2d 220, 2009 U.S. Dist. LEXIS 119482, 2009 WL 5102844 (S.D.N.Y. 2009).

Opinion

DECISION AND ORDER ON DEFENDANTS’ PRETRIAL MOTIONS

McMAHON, District Judge:

On February 24, 2009, a federal grand jury in this District returned and Filed Indictment 09 Cr. 168(CM) against defendants Harrison Brown, Allahvell Cutts, Henry Franklin, Malik Saunders, Rasheem Lee, John Sutton, Raheam Steed, Caleb Hooker, and Wajeeh Baker. Each defendant is named in at least one of the four charged narcotics distribution conspiracies, as well as in at least one of the thirteen substantive narcotics distribution counts arising out of the defendants’ participation in sales of cocaine base, commonly known as “crack,” and powder cocaine to undercover officers on thirteen different occasions in 2007 and 2008.

Defendants Harrison Brown, Allahvell Cutts, Henry Franklin, Malik Saunders, Rasheem Lee, Raheam Steed and Caleb Hooker have each filed motions asking the Court to rule that the individual defendants are improperly joined in the current indictment and that severance is warranted under Federal Rule of Criminal Procedure 8(b) and/or 14. Defendant Cutts also seeks suppression of various forms of evidence that was obtained from his residence or telephones pursuant to search warrants, suppression of statements made by him following arrest, and early disclosure of Brady and Giglio material related to witnesses in the case. 1

The Government opposes all of the defendants’ motions, except for defendantCutt’s motion to suppress his post arrest statements

Defendants’ Severance Motions

Each moving defendant argues that he should not be tried jointly with some or all of his codefendants. Each defendant asks that his case be severed from the other defendants.

Offenses and defendants are properly joined under Rule 8(b) where the criminal acts of two or more persons are “ ‘unified by some substantial identity of facts or participants’ or ‘arise out of a common plan or scheme.’ ” United States v. Attanasio, 870 F.2d 809, 815 (2d Cir.1989); Fed. R.Crim.P. 8(b). Rule 14 of the Federal Rules of Criminal Procedure permits severance in certain circumstances:

If the joinder of offenses or defendants in an indictment, an information, or a consolidation for trial appears to prejudice a defendant or the government, the court may order separate trials of counts, sever the defendants’ trials, or *223 provide any other relief that justice requires.

Fed.R.Crim.P. 14(a).

A defendant seeking severance must show that he would be so prejudiced by joinder that he would be denied a fair trial. United States v. Casamento, 887 F.2d 1141, 1149 (2d Cir.1989). It is not enough for a defendant to show that he “may have a better chance of acquittal in [a] separate trial[ ].” Zafiro v. United States, 506 U.S. 534, 540, 113 S.Ct. 933, 122 L.Ed.2d 317 (1993). “A district court should grant a severance under Rule 14 only if there is a serious risk that a joint trial would compromise a specific trial right of one of the defendants, or prevent the jury from making a reliable judgment about guilt or innocence.” Id. Even in those rare instances where a defendant establishes a “high” risk of prejudice, “less drastic measures, such as limiting instructions, often will suffice to cure any risk of prejudice.” Id. at 539, 113 S.Ct. 933 (citing Richardson v. Marsh, 481 U.S. 200, 211,107 S.Ct. 1702, 95 L.Ed.2d 176 (1987)); see also United States v. Feyrer, 333 F.3d 110,114 (2d Cir.2003).

The presumption in favor of joint trials “is particularly strong where the defendants are alleged to have participated in a common plan or scheme.” United States v. Salameh, 152 F.3d 88, 115 (2d Cir.1998). With respect to participants in the same charged conspiracy, any claim of “prejudicial spillover” does not justify severance because the evidence would be admissible at a separate trial of the moving defendant. Rather, undue “prejudice” may occur “when proof inadmissible against a defendant becomes a part of his trial solely due to the presence of co-defendants as to whom its admission is proper. This is an unlikely occurrence when all the defendants are charged under the same conspiracy count.” Salameh, 152 F.3d at 115 (citation omitted).

Although the defendants in the present case are not all named together in each of the conspiracies, the Government represents that the evidence at trial will demonstrate that the defendants are “ ‘unified by some substantial identity of facts or participants and a common plan.’ ” See Feyrer, 333 F.3d at 114 (quoting United States v. Attanasio, 870 F.2d 809, 815 (2d Cir.1989)). According to the Government, the evidence will show that each of the drug distribution operations that serve as the basis for the conspiracy charges in Counts One through Four is linked to Cutts or Brown or in the case of Count One, both Cutts and Brown — as suppliers and/or direct participants in the charged drug distribution conspiracies. Counts One, Three, and Four of the Indictment explicitly make this connection by listing Cutts, Brown, or both as members of the particular conspiracies charged. Each of the charges alleges that the defendants engaged in extremely similar conduct— sales of crack and/or powder cocaine at locations that are within close proximity to each other in the Bronx. In these circumstances, the parties and alleged acts are sufficiently linked to support joinder of each of the defendants under Rule 8(b).

In United States v. Halliman, 923 F.2d 873, 883 (D.C.Cir.1991), the D.C. Circuit found that two defendants who were charged with crack and cocaine sales in separate counts of an indictment were nonetheless properly joined under Rule 8(b). The Circuit Court held that the trial court properly relied on the Government’s proffer of the connections between the two defendants that it expected to show at trial in support of its pretrial ruling that joinder was proper. Id.; see also United States v. *224 De Yian, 94 Cr. 719(DLC), 1995 WL 368445, at *10 (S.D.N.Y. June 21, 1995). 2

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Cite This Page — Counsel Stack

Bluebook (online)
676 F. Supp. 2d 220, 2009 U.S. Dist. LEXIS 119482, 2009 WL 5102844, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-brown-nysd-2009.