United States v. Keenan Gibson

CourtCourt of Appeals for the Third Circuit
DecidedJune 21, 2022
Docket20-2759
StatusUnpublished

This text of United States v. Keenan Gibson (United States v. Keenan Gibson) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third 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. Keenan Gibson, (3d Cir. 2022).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 20-2759 _____________

UNITED STATES OF AMERICA

v.

KEENAN GIBSON, Appellant

_____________________________________

On Appeal from the United States District Court for the District of Delaware (District Court No. 1:16-cr-00046-001) District Court Judge: Richard G. Andrews _____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) June 7, 2022

(Filed: June 21, 2022)

Before: AMBRO, RENDELL, and FUENTES, Circuit Judges. _________ O P I N I O N* _________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. RENDELL, Circuit Judge.

Keenan Gibson appeals his conviction and sentence for possession of a firearm by

a felon in violation of 18 U.S.C. § 922(g)(1) and § 924(a)(2), possession of heroin with

the intent to distribute in violation of 21 U.S.C. § 841(a)(1) and § 841(b)(1)(C), and

possession of a firearm in furtherance of drug trafficking crime in violation of 18 U.S.C.

§ 924(c)(1)(A)(i). He raises two claims of error related to the evidence presented at

trial—the District Court erred in (1) concluding that a defense witness, Andre Strother,

could assert the Fifth Amendment privilege against self-incrimination, and (2) permitting

the Government to introduce certain testimony from police officers involved in Gibson’s

arrest—and a third concerning his sentencing—(3) the District Court misapprehended its

discretion when fashioning his sentences for his first two counts. Because we discern no

error in the District Court’s evidentiary rulings, we will affirm Gibson’s conviction. We,

however, will not affirm his sentence. On the record before us, we cannot conclude

whether the District Court erred during sentencing, so we will vacate his sentence and

remand for resentencing.

I.

In March 2016, the Wilmington Police Department deployed its Crisis

Management Tactical Team (the “Team”) to execute a search warrant at 2211 North

Washington Street in Wilmington, Delaware. During the search, officers encountered

Gibson, the only person in the apartment, and found a Ruger firearm and drugs, among

other things, in the apartment. Gibson was arrested and, several weeks later, indicted by

a federal grand jury on three counts: (1) possession of a firearm by a felon in violation of

2 18 U.S.C. § 922(g)(1) and § 924(a)(2); (2) possession of a controlled substance with the

intent to distribute in violation of 21 U.S.C. § 841(a)(1) and § 841(b)(1)(c); and

(3) possession of a firearm in furtherance of a drug trafficking crime in violation of 18

U.S.C. § 924(c)(1)(A)(i).1

The District Court conducted Gibson’s initial trial a few years later. During the

trial, the jury heard, among other things, evidence that another individual, Andre Strother,

purchased the Ruger recovered by the police, this firearm was not reported stolen, and it

was possible Strother still owned and possessed this firearm. The jury ultimately could

not reach a verdict, so the District Court declared a mistrial and scheduled a second trial

in June 2019.

Before the second trial, agents from the Bureau of Alcohol, Tobacco, Firearms and

Explosives (“ATF”) interviewed Strother about his purchase and possession of the Ruger

firearm. Strother admitted that he (1) purchased the firearm, (2) used drugs when he

purchased it although he did not use drugs at the time of the search, (3) had bought drugs

from Gibson at some point in the past, and (4) had been staying at Gibson’s apartment

near the time of the search. The Government disclosed the report memorializing this

interview to Gibson, and, before the second trial, at Gibson’s request, Strother was served

a subpoena to appear and testify.

1 The Government superseded the indictment in May 2019 without materially changing the charges.

3 The day after the second trial began, Strother informed the District Court that he

intended to assert his Fifth Amendment privilege in response to questions about either his

drug use or his ownership of the Ruger firearm. After Gibson challenged whether such

an assertion would be valid, the District Court permitted Gibson and the Government to

examine Strother outside the presence of the jury. During this examination, Strother

declined to answer most questions, invoking the privilege against self-incrimination. The

District Court determined that Strother validly invoked the privilege when questioned

about his drug use and the firearm. Because Strother could not offer any relevant

testimony outside of these two topics, the Court excused him from testifying.

Gibson’s second trial proceeded in two phases. During this first phase, which

concerned his counts for possession of heroin with the intent to distribute and possession

of a firearm in furtherance of a drug trafficking crime, the jury, among other things heard

testimony from officers explaining the execution of the search warrant at Gibson’s

residence, including the use of the Team. The jury found Gibson guilty of both counts.

The District Court then conducted the second phase, which pertained to the count for

possession of a firearm by a felon. The jury found Gibson guilty of this count as well.

The District Court later sentenced Gibson. He requested that the Court impose

two concurrent one-day sentences for his two counts of possession of a firearm by a felon

and possession of heroin with intent to distribute and a consecutive five-year mandatory

minimum sentence under 18 U.S.C. § 924(c)(1)(A)(i) for possession of a firearm in

furtherance of a drug trafficking crime. The District Court declined to grant this

requested variance. It sentenced Gibson to two concurrent 51-month terms of

4 imprisonment for his first two counts and one consecutive 60-month term of

imprisonment for his third count, but it noted that it would have sentenced Gibson to a

shorter term of imprisonment if the 60-month consecutive sentence was not required by

statute.

Gibson timely appealed his conviction and sentence.

II.2

A. Strother’s Invocation of the Fifth Amendment Privilege Against Self-Incrimination

We review the District Court’s application of the Fifth Amendment privilege

against self-incrimination de novo. United States v. Chabot, 793 F.3d 338, 342 (3d Cir.

2015). The Fifth Amendment privilege protects individuals when “compelled to produce

self-incriminating, testimonial communication[s].” Id. (alteration in original) (internal

quotation marks and citation omitted). It covers “more than just [giving] evidence which

may lead to [a] criminal conviction[;] [its protections] extend[] to information which

would furnish a link in the chain of evidence that could lead to a prosecution, as well as

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United States v. Keenan Gibson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-keenan-gibson-ca3-2022.