United States v. Giles

CourtDistrict Court, District of Columbia
DecidedOctober 19, 2020
DocketCriminal No. 2019-0311
StatusPublished

This text of United States v. Giles (United States v. Giles) 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. Giles, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : : v. : Criminal Action No.: 19-311 (RC) : SAMUEL GILES, : Re Document Nos.: 21, 22, 33, 34 : Defendant. :

MEMORANDUM OPINION

DENYING DEFENDANT’S MOTION TO DISMISS; DENYING DEFENDANT’S MOTION TO SUPPRESS; AND GRANTING IN PART AND DENYING IN PART GOVERNMENT’S MOTION TO INTRODUCE EVIDENCE UNDER FEDERAL RULES OF EVIDENCE 404(B) AND 609

I. INTRODUCTION

Defendant Samuel Giles is charged with being a felon in possession of a firearm. He has

moved to dismiss the indictment against him and suppress physical evidence that he argues was

obtained in violation of the Fourth Amendment. See Mot. to Dismiss, ECF No. 33; Mot. to

Suppress, ECF No. 34. In addition, the Government has filed a motion in limine seeking to

introduce evidence of Giles’s past convictions at trial under Federal Rules of Evidence 404(b)

and 609. See Gov’t Mot. in Lim., ECF Nos. 21. The Court held an evidentiary hearing on

September 18, 2020, to take evidence on Giles’s motion to suppress. See Minute Entry (Sept.

18, 2020); Evidentiary Hr’g Tr.

For the reasons stated below, the Court will deny Giles’s motions to dismiss and

suppress. It will also grant in part and deny in part the Government’s motion in limine.

II. BACKGROUND

In the early morning of September 2, 2019, three police officers with the Metropolitan

Police Department (“MPD”) were on patrol in southeast Washington, D.C. Evidentiary Hr’g Tr. at 9–10. Officers James Wilson, Brandon Varone, and Mikal Barnes were sitting in a parked

squad car when they saw a dark-colored Dodge sedan drive by without a license plate on its front

bumper. See id. at 9–10, 42. The officers pulled out of the parking lot where they were parked

to follow the sedan, which then turned off the main road. Id. at 42–43. When the officers

discovered the sedan parked without its lights on in an alleyway, the sedan began to move

forward. Id. at 18–19. The officers activated their squad car’s emergency lights and “g[ave]

loud verbal commands . . . to stop the vehicle.” 1 See id. at 19.

After continuing to drive onward for a few moments, Giles exited the sedan, asked the

officers why they were pulling him over, and ran down the street. Id. at 19. Barnes noticed that

Giles was clutching something black to his waistband, but he could not tell what it was. Id. at

23. Wilson and Varone exited the squad car and chased Giles. Id. at 20. Meanwhile, the sedan

had begun to roll backwards, so Barnes reversed the squad car to get out of the way. Id. When

the sedan stopped moving, Barnes ran over to it and put it in park. Id. The engine was still

running. Id. at 21. Barnes then joined Wilson and Varone, who were trying to put Giles in

handcuffs in a field across the street. Id. Barnes testified that the officers pepper sprayed Giles

because he was resisting. Id. at 24–25. The officers eventually subdued Giles and placed him

under arrest. Id.

Soon, several other police officers and some paramedics arrived at the scene. See id.

While paramedics treated Giles across the street, Varone discovered a black fanny pack and a

knife in the field where Giles was handcuffed. Gov’t Ex. 6, Varone’s Body-Worn Camera

1 Sometime earlier in their patrol, the MPD officers had received an alert identifying the license plate on back of the sedan as stolen. Evidentiary Tr. at 12–13, 40. But Barnes testified that he had not seen the sedan’s back plate or “ma[d]e the connection between” the stolen plate alert and the sedan until after attempting to initiate the traffic stop. Id. at 42–43. As it turns out, the alert was incorrect; the plate had not been stolen. Id. at 57–59, 65.

2 Footage (“Gov’t Ex. 6”) at 26:00–26:15. Varone walked over to Giles and asked, “Before I look

in that bag—what’s in that bag over there?” Id. at 29:29–31. Giles responded, “What bag? . . . .

Y’all patted me down—I ain’t have no bag.” Id. at 29:31–35. Varone repeated, “The bag that

you dropped when we were scuffling in the exact location where you’re at—what’s in that bag

next to the knife over there?” Id. at 29:35–29:42. Giles again denied having a bag. See id. at

29:42–44 (“I didn’t have no [indecipherable].”). Varone and Wilson then opened the fanny

pack. Id. at 32:36–52. Inside were a handgun, ammunition, and Giles’s identification card.

Evidentiary Hr’g Tr. at 30–31; Gov’t Omnibus Opp’n to Mots. to Dismiss and Suppress (“Gov’t

Omnibus Opp’n”) at 3, ECF No. 43. A federal grand jury indicted Giles for unlawful possession

of a firearm by a felon in violation of 18 U.S.C. § 922(g)(1). Indictment at 1, ECF No. 1.

III. ANALYSIS

A. Motion to Dismiss

Giles moves to dismiss the indictment on the grounds that the Government will be unable

to establish a chain of custody for the firearm it alleges he illegally possessed. Mot. to Dismiss

at 1–2. The premise of his argument is that neither of the police officers who discovered the

firearm would be able to testify. See id. at 4; see also United States v. Mitchell, 816 F.3d 865,

871 (D.C. Cir. 2016) (“It is generally recognized that tangible objects become admissible in

evidence only when proof of their original acquisition and subsequent custody forges their

connection with the accused and the criminal offense.” (emphasis added) (citation omitted)).

Wilson resigned and moved away from the District of Columbia; Varone was injured in a car

accident. See Notice ¶¶ 4, 6, 8, ECF No. 27. But the Government has informed the Court that

Varone has recovered from his injuries and is prepared to testify. See Evidentiary Hr’g Tr. at 7.

Because Giles’s motion to dismiss depended on Varone’s absence, the motion is denied as moot.

3 B. Motion to Suppress

In his motion to suppress, Giles argues that the evidence discovered in the fanny pack—

most significantly, the gun and ammunition—were fruits of the poisonous tree and should be

suppressed. 2 Mot. to Suppress at 1, 4. Under the fruit-of-the-poisonous-tree doctrine, “evidence

that would likely not have been found but for a Fourth Amendment violation must usually be

suppressed.” United States v. Peyton, 745 F.3d 546, 556 (D.C. Cir. 2014). Giles asserts that two

violations of his Fourth Amendment rights led to officers discovering the gun and ammunition.

First, he says that the police officers unlawfully seized him when they conducted the traffic stop.

Id. at 8. Second, he challenges the officers’ search of the fanny pack as unlawful. Id. at 8–9.

The Court examines each of his arguments in turn.

1. The Traffic Stop

A traffic stop is a “seizure” under the Fourth Amendment. Whren v. United States, 517

U.S. 806, 809 (1996). But “the decision to stop an automobile is reasonable”—and therefore

constitutional—“where the police have probable cause to believe that a traffic violation has

occurred.” Id. at 810. That is true “even if the offense is a minor one.” United States v.

Mitchell, 951 F.2d 1291, 1295 (D.C. Cir. 1991) (approving traffic stop when officer witnessed

defendant speed and fail to signal a turn). And importantly, reasonableness is assessed against

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