United States v. John Battle

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 25, 2023
Docket18-4768
StatusUnpublished

This text of United States v. John Battle (United States v. John Battle) 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. John Battle, (4th Cir. 2023).

Opinion

USCA4 Appeal: 18-4768 Doc: 56 Filed: 07/25/2023 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 18-4768

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JOHN DEVERE BATTLE, a/k/a Gotti,

Defendant - Appellant.

Appeal from the United States District Court for the Eastern District of North Carolina, at Raleigh. Malcolm J. Howard, Senior District Judge. (5:17-cr-00111-H-1)

Submitted: June 30, 2023 Decided: July 25, 2023

Before KING and QUATTLEBAUM, Circuit Judges, and MOTZ, Senior Circuit Judge.

Affirmed in part, vacated in part and remanded by unpublished per curiam opinion.

ON BRIEF: W. Michael Dowling, THE DOWLING FIRM PLLC, Raleigh, North Carolina, for Appellant. Kenneth A. Polite, Jr., Assistant Attorney General, Lisa H. Miller, Deputy Assistant Attorney General, Daniel Noah Lerman, Criminal Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Michael F. Easley, Jr., United States Attorney, David A. Bragdon, Appellate Chief, OFFICE OF THE UNITED STATES ATTORNEY, Raleigh, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 18-4768 Doc: 56 Filed: 07/25/2023 Pg: 2 of 6

PER CURIAM:

John Devere Battle appeals his convictions imposed following a jury trial on charges

of conspiracy to commit Hobbs Act robbery, in violation of 18 U.S.C. § 1951; two courts

of aiding and abetting Hobbs Act robbery, in violation of 18 U.S.C. §§ 2, 1951; four counts

of aiding and abetting brandishing a firearm in furtherance of a crime of violence, in

violation of 18 U.S.C. §§ 2, 924(c); aiding and abetting carjacking, in violation of 18 U.S.C.

§§ 2, 2119; aiding and abetting bank robbery, in violation of 18 U.S.C. §§ 2, 2113; and two

counts of possession of a firearm and ammunition by a convicted felon, in violation of 18

U.S.C. § 922(g)(1). Following his convictions, the district court sentenced Battle to 1,276

months’ imprisonment. For the following reasons, we affirm Battle’s convictions but

vacate his sentence and remand for resentencing.

On appeal, Battle first argues that the district court abused its discretion and violated

his rights under the Sixth Amendment’s Confrontation Clause when it restricted him from

asking two cooperating codefendants about the specific sentences they avoided or hoped

to receive in exchange for their cooperation and about their anticipated Sentencing

Guidelines ranges. We disagree.

“[A] defendant’s right to cross-examine cooperating witnesses about sources of

potential bias is guaranteed by the Confrontation Clause of the Constitution.” United

States v. Cropp, 127 F.3d 354, 358-59 (4th Cir. 1997). “We review for abuse of discretion

a trial court’s limitations on a defendant’s cross-examination of a prosecution witness.”

United States v. Ramos-Cruz, 667 F.3d. 487, 500 (4th Cir. 2012) (internal quotation marks

omitted). A district court abuses its discretion by basing its decision on clearly erroneous

2 USCA4 Appeal: 18-4768 Doc: 56 Filed: 07/25/2023 Pg: 3 of 6

findings of fact or by misapprehending the law. United States v. Zayyad, 741 F.3d 452,

458 (4th Cir. 2014). However, a district court has wide latitude in imposing limits on the

cross-examination of a witness, and may impose such limits to avoid harassment, prejudice,

confusion of the issues, repetition, or marginal relevance. Id. at 459.

“[T]he exposure of a witness’ motivation in testifying is a proper and important

function of the constitutionally protected right of cross-examination.” Davis v. Alaska, 415

U.S. 308, 316-17 (1974). And “[a] witness’[] understanding of the potential penalties faced

prior to entering into a plea agreement may demonstrate bias and prejudice, as well as the

motive of the witness for testifying against the defendant and for the prosecution.” United

States v. Turner, 198 F.3d 425, 430 (4th Cir. 1999). But while a defendant may ask a

cooperating witness whether he hopes to receive some benefit in exchange for his

testimony, a district court may generally prohibit the defendant from asking questions

about the “specific penalties” the witness avoided by pleading guilty, as well as questions

about the “mechanics of the Guidelines” or specific Guidelines ranges. Cropp, 127 F.3d

at 358-359; see United States v. Scheetz, 293 F.3d 175, 184 (4th Cir. 2002) (holding that

the “district court did not err in refusing to allow Scheetz’s counsel to ask questions

concerning Sentencing Guidelines ranges”). Here, the district court did not prevent Battle

from asking the cooperating codefendants whether they expected to receive some benefit

in exchange for their testimony, instead ruling only that Battle could not ask about specific

sentences or delve into the mechanics of the Sentencing Guidelines. We therefore find that

the district court did not violate Battle’s right under the Confrontation Clause or otherwise

abuse its discretion.

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Battle next argues that the district court should have granted his motion for judgment

of acquittal on the 18 U.S.C. § 924(c) charge arising from his participation in the June 15,

2016, robbery of a Quality Mart convenience store. Battle argues that there was

insufficient evidence to show he aided and abetted the brandishing of a firearm during the

robbery because there was no evidence showing he had advance knowledge his

accomplices would be armed.

“We review the denial of a motion for judgment of acquittal de novo.” United

States v. Savage, 885 F.3d 212, 219 (4th Cir. 2018). In assessing the sufficiency of the

evidence, we determine whether there is substantial evidence to support the conviction

when viewed in the light most favorable to the government. Id. “Substantial evidence is

evidence that a reasonable finder of fact could accept as adequate and sufficient to support

a conclusion of a defendant’s guilt beyond a reasonable doubt.” United States v.

Rodriguez-Soriano, 931 F.3d 281, 286 (4th Cir. 2019) (cleaned up). In making this

determination, we do not resolve conflicts in the evidence or evaluate witness credibility.

Savage, 885 F.3d at 219. “A defendant who brings a sufficiency challenge bears a heavy

burden, as appellate reversal on grounds of insufficient evidence is confined to cases where

the prosecution’s failure is clear.” Id. (internal quotation marks omitted).

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Related

Davis v. Alaska
415 U.S. 308 (Supreme Court, 1974)
United States v. Israel Ramos-Cruz
667 F.3d 487 (Fourth Circuit, 2012)
United States v. Eric Michael Turner, A/K/A Boo
198 F.3d 425 (Fourth Circuit, 1999)
United States v. Awni Shauaib Zayyad
741 F.3d 452 (Fourth Circuit, 2014)
Rosemond v. United States
134 S. Ct. 1240 (Supreme Court, 2014)
United States v. Scheetz
293 F.3d 175 (Fourth Circuit, 2002)
United States v. Khan
461 F.3d 477 (Fourth Circuit, 2006)
United States v. Junaidu Savage
885 F.3d 212 (Fourth Circuit, 2018)
United States v. Christopher Rodriguez-Soriano
931 F.3d 281 (Fourth Circuit, 2019)
United States v. Zavian Jordan
952 F.3d 160 (Fourth Circuit, 2020)
United States v. Joseph Benson
957 F.3d 218 (Fourth Circuit, 2020)
United States v. Cortez Rogers
961 F.3d 291 (Fourth Circuit, 2020)
United States v. Christopher Singletary
984 F.3d 341 (Fourth Circuit, 2021)
Christopher Payne v. Jahal Taslimi
998 F.3d 648 (Fourth Circuit, 2021)

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