United States v. Jose Aguirre-Cuenca

CourtCourt of Appeals for the Fourth Circuit
DecidedJanuary 18, 2023
Docket21-4307
StatusUnpublished

This text of United States v. Jose Aguirre-Cuenca (United States v. Jose Aguirre-Cuenca) 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. Jose Aguirre-Cuenca, (4th Cir. 2023).

Opinion

USCA4 Appeal: 21-4307 Doc: 54 Filed: 01/18/2023 Pg: 1 of 7

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 21-4307

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

JOSE AGUIRRE-CUENCA,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Frank D. Whitney, District Judge. (3:19-cr-00141-FDW-DCK-1)

Submitted: November 18, 2022 Decided: January 18, 2023

Before AGEE, DIAZ, and HARRIS, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Anthony Martinez, Federal Public Defender, Megan C. Hoffman, Assistant Federal Public Defender, FEDERAL DEFENDERS OF WESTERN NORTH CAROLINA, INC., Charlotte, North Carolina, for Appellant. Dena J. King, United States Attorney, Anthony J. Enright, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charlotte, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 21-4307 Doc: 54 Filed: 01/18/2023 Pg: 2 of 7

PER CURIAM:

Jose Aguirre-Cuenca, convicted of unlawful reentry after deportation and a firearm-

possession charge, appeals the denial of a suppression motion. We find no clear error in

the factual findings on which the district court relied to deny Aguirre-Cuenca’s motion.

And Aguirre-Cuenca’s additional arguments for suppression, brought for the first time on

appeal, are waived. Accordingly, we affirm the judgment of the district court.

I.

At approximately 4:00 a.m. on April 20, 2019, Officer Ryan Tran-Thompson of the

Charlotte-Mecklenburg Police Department responded to a report that a car was stopped in

the road after striking a pole. When Tran-Thompson arrived, defendant Jose Aguirre-

Cuenca was sitting in the driver’s seat of a sedan parked partly in the roadway. Tran-

Thompson exited his patrol car and walked toward Aguirre-Cuenca’s vehicle.

The parties dispute what happened next. According to Officer Tran-Thompson, as

he approached the car, he saw the defendant reach for the back-seat floorboard, where

several beers were visible. Tran-Thompson claims that the defendant then voluntarily

exited his car and walked toward the officer with his hands in his pockets, seemingly

intoxicated. Aguirre-Cuenca, meanwhile, denies reaching into the back seat, and contends

that Tran-Thompson ordered him out of the car. Tran-Thompson had not yet activated his

body camera, so this portion of the encounter was not recorded. The parties agree that

departmental policy requires officers to activate their body cameras prior to arrival at any

call for service, and that Tran-Thompson violated this policy.

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After Aguirre-Cuenca exited the car, Tran-Thompson requested that he remove his

hands from his pockets. But Aguirre-Cuenca repeatedly placed his hand back in his left

pants pocket, as though “pushing something down to conceal it.” J.A. 68. At this point,

Tran-Thompson activated his body camera and conducted a frisk of Aguirre-Cuenca’s left

pocket. The officer identified a bullet seated in a magazine, at which point he placed

Aguirre-Cuenca in handcuffs.

Soon thereafter, two other officers arrived on the scene. Tran-Thompson relayed

that Aguirre-Cuenca had a magazine in his pocket and several beers in the back seat of his

car. After observing the open containers, the officers searched the car’s cabin and

recovered a black handgun wrapped in a shirt.

Aguirre-Cuenca was then arrested and charged with unlawfully reentering the

country after deportation, 8 U.S.C. § 1326(a), and possession of a firearm “knowing that

he was an alien unlawfully and illegally in the United States,” J.A. 10; see 18 U.S.C.

§ 922(g)(5)(A). Aguirre-Cuenca moved to suppress evidence of the firearm, arguing that

his Fourth Amendment rights were violated when Tran-Thompson ordered him to exit his

car without probable cause or reasonable suspicion of a crime. He also argued that Tran-

Thompson’s failure to activate his body camera upon arrival constituted bad-faith

destruction of evidence warranting suppression or an adverse inference as to Tran-

Thompson’s credibility. See Arizona v. Youngblood, 488 U.S. 51 (1988).

After a hearing, the magistrate judge credited Tran-Thompson’s testimony that

Aguirre-Cuenca left his vehicle voluntarily, and so rejected the defendant’s argument that

all evidence subsequently discovered must be excluded as fruit of an unreasonable seizure.

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And the magistrate judge concluded that Tran-Thompson’s failure to activate his body

camera, though contrary to departmental policy, did not constitute bad-faith destruction of

evidence. Again, the magistrate judge credited Tran-Thompson’s testimony, finding that

the officer was not motivated by any improper desire to withhold exculpatory evidence

when – approaching what he believed to be no more than the scene of an accident – he did

not immediately activate his camera. The magistrate judge went on to approve the officers’

subsequent frisk of Aguirre-Cuenca and search of his vehicle as reasonable under the

Fourth Amendment. Accordingly, the magistrate judge recommended that the district court

deny the defendant’s motion to suppress evidence of the firearm.

Before the district court, Aguirre-Cuenca objected to the magistrate’s

recommendation on only two grounds: first, that he had not voluntarily exited his vehicle;

and second, that Tran-Thompson had acted in bad faith when he failed to activate his

camera, requiring, at a minimum, that the district court accept the defendant’s account of

events. The district court reviewed those two objections de novo, affirmed the magistrate

judge’s determinations, and adopted the recommendation to deny the motion to suppress.

After a stipulated bench trial, the district court convicted Aguirre-Cuenca on both

counts. The court sentenced the defendant to time served and a one-year term of supervised

release. Aguirre-Cuenca appealed on the sole ground that the district court erred in denying

his motion to suppress.

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II.

On appeal, Aguirre-Cuenca reprises his arguments before the magistrate judge and

district court. He also contends, for the first time, that even assuming he voluntarily left

his car – so that the encounter did not begin with an unconstitutional seizure – the officers

subsequently violated his Fourth Amendment rights when they frisked his pocket and

searched his vehicle without adequate justification. But those issues were not raised in

Aguirre-Cuenca’s motion to suppress, and the defendant did not object to those portions of

the magistrate judge’s recommendation. Under Federal Rule of Criminal Procedure

59(b)(2), failure to “file specific written objections to the proposed findings and

recommendations” of a magistrate judge “waives a party’s right to review” of those

findings. Fed. R. Crim. P. 59

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United States v. Jose Aguirre-Cuenca, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-jose-aguirre-cuenca-ca4-2023.