United States v. Derrick Daniels, Jr.

41 F.4th 412
CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 25, 2022
Docket19-4812
StatusPublished

This text of 41 F.4th 412 (United States v. Derrick Daniels, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Derrick Daniels, Jr., 41 F.4th 412 (4th Cir. 2022).

Opinion

USCA4 Appeal: 19-4812 Doc: 50 Filed: 07/25/2022 Pg: 1 of 6

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 19-4812

UNITED STATES OF AMERICA,

Plaintiff – Appellee,

v.

DERRICK ALAN DANIELS, JR.,

Defendant – Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Robert J. Conrad, Jr., District Judge. (3:17-cr-00124-RJC-DSC-1)

Argued: December 9, 2021 Decided: July 25, 2022

Before RICHARDSON and RUSHING, Circuit Judges, and TRAXLER, Senior Circuit Judge.

Affirmed by published opinion. Judge Richardson wrote the opinion in which Judge Rushing and Senior Judge Traxler joined.

ARGUED: Joshua B. Carpenter, FEDERAL DEFENDERS OF WESTERN NORTH CAROLINA, INC., Asheville, North Carolina, for Appellant. Anthony Joseph Enright, OFFICE OF THE UNITED STATES ATTORNEY, Charlotte, North Carolina, for Appellee. ON BRIEF: Anthony Martinez, Federal Public Defender, Ann L. Hester, Assistant Federal Public Defender, FEDERAL DEFENDERS OF WESTERN NORTH CAROLINA, INC., Charlotte, North Carolina, for Appellant. William T. Stetzer, Acting United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charlotte, North Carolina, for Appellee. USCA4 Appeal: 19-4812 Doc: 50 Filed: 07/25/2022 Pg: 2 of 6

RICHARDSON, Circuit Judge:

Derrick Daniels challenges the admissibility of a handgun found in a rental car he

had been driving that was parked outside of his hotel. But Daniels lacked a legitimate

expectation of privacy in the car because he introduced no evidence that he was in lawful

possession of the car. So he could not challenge the search. We thus affirm the district

court’s denial of his motion to suppress the handgun.

I. Background

Derrick Daniels had multiple outstanding arrest warrants, and police were actively

searching for him. So they obtained search warrants to track him using his cell-phone

location data. After using that data to find him, officers saw Daniels driving a gray Dodge

Charger with a Florida license tag. Running the license plate on the vehicle revealed that

the Charger was an Enterprise rental car.

The next morning, officers tracked Daniels to a Baymont Inn & Suites and found

the Charger parked out front. The desk clerk directed the officers to Daniels’ hotel room,

where they arrested Daniels based on the outstanding arrest warrants.

As Daniels was walked out of the hotel, he passed the Charger. An officer asked

Daniels if he knew anything about the vehicle without having provided a Miranda warning.

Daniels responded that “he didn’t know anything about a Dodge Charger.” J.A. 142.

Knowing the Charger was a rental vehicle, an officer called Enterprise about the

car. The officer spoke with an Enterprise risk manager. The risk manager testified that the

officer told her “they were making an arrest of the person who had [Enterprise’s] vehicle

and asked what [she] would like to do with the vehicle.” J.A. 217. Upon checking the

2 USCA4 Appeal: 19-4812 Doc: 50 Filed: 07/25/2022 Pg: 3 of 6

rental agreement, the risk manager discovered that Daniels did not rent the car and was not

listed as an authorized driver. 1 Instead, the authorized renter was Erica Baldwin. Under

the rental agreement, Enterprise had the right to seize the car without notice to the renter

whenever it discovered that an unauthorized person drove the vehicle. So the risk manager

sent a tow truck to return the vehicle to Enterprise’s service center.

Officers followed the tow truck to Enterprise to be present if an Enterprise employee

discovered contraband. At the service center, Enterprise’s employees consented to a search

of the vehicle. 2 After a handgun was discovered under the driver’s side floor mat, a team

of crime-scene specialists arrived to collect the firearm, and DNA analysis on the gun

revealed Daniels’ DNA.

Based on the gun recovered from the Charger, a grand jury indicted Daniels for

possession of a firearm by a felon under 18 U.S.C. § 922(g)(1). Daniels moved to suppress

the evidence from the Charger on the theory that it was obtained from an unlawful search

1 In briefing below, Daniels’ counsel alleged that Daniels paid the deposit for the rental car, but no evidence was introduced to support that claim. 2 The officers and Enterprise employees offered somewhat different, and at times contradictory, accounts of the sequence of events at Enterprise’s service center and exactly when consent was given. But acknowledging the “discrepancy between the witnesses as to how that search transpired, [and] the mechanics of the search” the district court still made a factual finding that “Enterprise had the authority to give consent and gave valid consent.” J.A. 264–65. So we defer to the district court’s factual finding. And although Daniels argues that Enterprise’s consent was not valid, he does not argue that Enterprise did not give consent.

3 USCA4 Appeal: 19-4812 Doc: 50 Filed: 07/25/2022 Pg: 4 of 6

in violation of the Fourth Amendment. A suppression hearing followed. 3 Finding that

Daniels had abandoned any legitimate expectation of privacy in the Charger, that

Enterprise had given valid third-party consent to the search, and that the Government

would have inevitably discovered the gun in the Charger, the district court denied Daniels’

motion to suppress. Daniels then entered a conditional plea, preserving his right to appeal

the adverse ruling on his suppression motion.

II. Discussion

The Fourth Amendment guards “against unreasonable searches and seizures.” U.S.

Const. amend. IV. To challenge the legality of a search under the Fourth Amendment, a

criminal defendant must prove that he has a “legitimate expectation of privacy” in the item

or area searched. Rawlings v. Kentucky, 448 U.S. 98, 104 (1980). “A person who is

aggrieved by an illegal search . . . of a third person’s premises or property has not had any

of his Fourth Amendment rights infringed.” Rakas v. Illinois, 439 U.S. 128, 134 (1978).

To determine whether a legitimate expectation of privacy exists, we look to

“concepts of real or personal property law or to understandings that are recognized and

permitted by society.” Byrd v. United States, 138 S. Ct. 1518, 1527 (2018) (quoting Rakas,

3 At first, the district court denied Daniels’ suppression motion without a suppression hearing, under then-prevailing precedent that unauthorized drivers of a rental car “had no legitimate privacy interest in the car.” J.A. 61–62 (citing United States v. Wellons, 32 F.3d 117, 119–20 (4th Cir. 1994)). But before he was sentenced, the Supreme Court rejected Wellons’ “per se rule” that “drivers who are not listed on rental agreements always lack an expectation of privacy in the automobile based on the rental company’s lack of authorization alone.” See Byrd v. United States, 138 S. Ct. 1518, 1526–27, 1531 (2018). So Daniels moved the district court to reconsider its prior ruling. Following a suppression hearing, the district court again denied Daniels’ suppression motion. It is from that second denial that Daniels now appeals. 4 USCA4 Appeal: 19-4812 Doc: 50 Filed: 07/25/2022 Pg: 5 of 6

439 U.S.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
41 F.4th 412, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-derrick-daniels-jr-ca4-2022.