United States v. Gaskins

CourtDistrict Court, District of Columbia
DecidedApril 12, 2023
DocketCriminal No. 2004-0379
StatusPublished

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

Bluebook
United States v. Gaskins, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA,

v. Case No. 04-cr-379-RCL-6 AL VIN M. GASKINS,

Defendant.

MEMORANDUM ORDER

The Court and the parties met recently to discuss next steps in potential discovery regarding

Defendant Alvin Gaskins' pending certificate of innocence. During the status conference, the

Court stated that an order addressing such discovery would be forthcoming. This is that order.

Specifically, the Court will order the government to produce unredacted copies of certain Federal

Bureau of Investigation ("FBI") records and bank records related to Dream Team Investigations

("DTI"). Additionally, Gaskins will be permitted to submit limited interrogatories and document

requests in accordance with the Federal Rules of Civil Procedure.

I. BACKGROUND

In 2004, Alvin Gaskins and twenty other defendants were charged with various crimes

related to a narcotics-distribution conspiracy that operated in the District of Columbia, Maryland,

and Virginia between 1999 and 2004. United States v. Gaskins ("Gaskins I"), 690 F.3d 569, 572

(D.C. Cir. 2012). In 2006, Gaskins and three codefendants-Gerald Eiland, Frederick Miller, and

Robert Bryant-went to trial. Id. at 572. The jury found Gaskins guilty of conspiracy to distribute

more than 100 grams but less than one kilogram of heroin. Id. at 576. In 2008, this Court sentenced

Gaskins to 262 months ofincarceration. See id. Gaskins appealed and, in 2012, the Circuit reversed

the conviction after finding that it was not supported by sufficient evidence. Id. at 576, 582. In

1 total, Gaskins served almost eight years of his nearly twenty-two-year sentence before his release.

United States v. Gaskins ("Gaskins II"), No. l:04-cr-379 (RCL), 2019 WL 7758898, at *1 (D.D.C.

Dec. 13, 2019).

In 2017, Gaskins moved in this Court for a certificate of innocence, pursuant to 28 U.S.C.

§ 2513 . Def.'s Mot. for Certificate oflnnocence, ECF No. 1237. The government opposed. Gov't

Opp'n, ECF No. 1242. Nearly a year later, Gaskins moved for the Court to open limited discovery

and set an evidentiary hearing on the motion. Mot. for Disc. & for Evidentiary Hr'g, ECF No.

1257. The Court denied Gaskins' motion for certificate of innocence without ruling on his

discovery or evidentiary hearing requests. See generally Gaskins II, 2019 WL 7758898. Gaskins

appealed and, in 2021, the Circuit vacated this Court's order and remanded the case for this Court

to address Gaskins' procedural motion. 1 United States v. Gaskins ("Gaskins III"), 6 F.4th 1350

(D.C. Cir. 2021). According to the Circuit, "Gaskins' requests aimed at developing the key factual

issue of his own state of mind," even though the Circuit acknowledged that "with 'an inchoate

crime like conspiracy, ... your best evidence' is '[w]hat is in Mr. Gaskins' mind."' Id. at 1362-

63 (citing Oral Arg. Tr. at 24:21-22, 36:14-15).

On February 2, 2023, the Court and the parties met for a status conference to discuss next

steps on remand. Minute Entry (02/07/2023). The Court ordered the parties to meet and confer

regarding a proposed scheduling order for discovery. On March 22, 2023, the parties jointly

submitted an update detailing their conversations regarding, and disagreements about, the content

and scope of the limited discovery. ECF No. 1308. On March 24, 2023, the Court and the parties

1 Key to the Circuit's reasoning appears to be the fact that the government did not oppose Gaskins' discovery request either in their briefing or at oral argument. See, e.g., United States v. Gaskins ("Gaskins III"), 6 F.4th 1350, 1357 (D.C. Cir. 2021) ("The government never opposed Gaskins' motion for limited discovery and an evidentiary hearing"); id. at 1364 ("The government's acquiescence to Gaskins' procedural requests naturally raises the prospect of their being granted"). At oral argument, the government explained that it did not respond to Gaskins' motion because the Court had not ordered a response. See Oral Arg. Rec. at 27 :50- 28:05 .

2 met again for a status conference and to discuss their disagreements and proposed next steps.

Minute Entry (03/24/2023). Among the topics discussed at that status conference were the

applicability of the Federal Rules of Civil Procedure and whether the documents that Gaskins

requests, if any, are discoverable.

II. DISCUSSION

The Court will lay out the legal standards applying to discovery in certificate of innocence

proceedings and provide the parties guidance on moving forward with discovery in this case.

A. Civil Discovery Rules Apply to This Case

As a threshold matter, the Court must address what standards govern discovery here. In

Gaskins' procedural motion, he asked the Court to apply the "rules and legal theories applicable

to civil discovery principles." Mot. for Disc. & for Evidentiary Hr'g at 3. The case that Gaskins

cites for this proposition, Pulungan v. United States, 722 F.3d 983, 986 (7th Cir. 2013), does not

specifically state that the traditional civil discovery rules apply to a certificate of innocence

proceeding. At the March 24, 2023 status conference, the government stated that it did not believe

that the civil discovery rules apply to this case. Status Conference Tr. (Draft) at 5:5-7. This is a

novel issue, with no case resolving the matter.

The Federal Rules of Civil Procedure plainly control here because (1) the petition for a

certificate of innocence is a civil proceeding and (2) the Federal Rules of Civil Procedure apply to

all civil actions and proceedings unless Congress or the Supreme Court has made a specific

exception, and no exception has been made for this type of proceeding. For the first point, this

Court previously remarked, "[a] petition for a certificate of innocence is civil in nature" and that

"[u ]nlike in a criminal action, the party seeking the certificate bears the burden of proof and must

prove his case by a preponderance of the evidence." Gasldns II, 2019 WL 7758898, at *1 (citing

3 Betts v. United States, 10 F.3d 1278, 1283 (7th Cir. 1993) and United States v. Grubbs, 773 F.3d

726, 732-33 (6th Cir. 2014)); see Abu-Shawish v. United States, 898 F.3d 726, 736 (7th Cir. 2018)

("A petition [for a certificate of innocence] starts what is, in essence, a civil proceeding within the

closed criminal case."). The Circuit indicated that it shares this view. See Gaskins III, 6 F.4th at

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Related

Crawford-El v. Britton
523 U.S. 574 (Supreme Court, 1998)
John A. Betts v. United States
10 F.3d 1278 (Seventh Circuit, 1993)
United States v. Alvin Gaskins
690 F.3d 569 (D.C. Circuit, 2012)
Mobley v. Central Intelligence Agency
924 F. Supp. 2d 24 (District of Columbia, 2013)
Doli Syarief Pulungan v. United States
722 F.3d 983 (Seventh Circuit, 2013)
United States v. Ernest Grubbs
773 F.3d 726 (Sixth Circuit, 2014)
Mhammad Abu-Shawish v. United States
898 F.3d 726 (Seventh Circuit, 2018)
United States v. Alvin Gaskins
6 F.4th 1350 (D.C. Circuit, 2021)
In re Navy Chaplaincy
323 F. Supp. 3d 25 (D.C. Circuit, 2018)
Alexander v. Federal Bureau of Investigation
192 F.R.D. 23 (District of Columbia, 2000)

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