United States v. Quinton Littlejohn

CourtCourt of Appeals for the Fourth Circuit
DecidedJuly 25, 2023
Docket20-4045
StatusUnpublished

This text of United States v. Quinton Littlejohn (United States v. Quinton Littlejohn) 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. Quinton Littlejohn, (4th Cir. 2023).

Opinion

USCA4 Appeal: 20-4045 Doc: 54 Filed: 07/25/2023 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 20-4045

UNITED STATES OF AMERICA,

Plaintiff - Appellee,

v.

QUINTON OSHUMOND LITTLEJOHN,

Defendant - Appellant.

Appeal from the United States District Court for the Western District of North Carolina, at Charlotte. Robert J. Conrad, Jr., District Judge. (3:18-cr-00140-RJC-DSC-1)

Submitted: March 28, 2023 Decided: July 25, 2023

Before WYNN and HEYTENS, Circuit Judges, and TRAXLER, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Roderick M. Wright, Jr., WRIGHT LAW FIRM OF CHARLOTTE, PLLC, Charlotte, North Carolina, for Appellant. Dena J. King, United States Attorney, Charlotte, North Carolina, Amy E. Ray, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Asheville, North Carolina, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 20-4045 Doc: 54 Filed: 07/25/2023 Pg: 2 of 6

PER CURIAM:

Quinton Oshumond Littlejohn appeals his conviction following a jury trial for being

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

1); possessing with intent to distribute at least 28 grams of cocaine base, in violation of 21

U.S.C. § 841(a)(1), (b)(1)(B) (Count 2); and possessing a firearm in furtherance of a drug

trafficking crime, in violation of 18 U.S.C. § 924(c)(1)(A) (Count 3). Littlejohn argues on

appeal that the district court erred in denying him a Franks ∗ hearing and denying his motion

to suppress, that the court erroneously admitted prior bad act testimony, that the jury

instructions were erroneous, that his conviction on Count 3 for possessing a firearm in

furtherance of a drug trafficking crime is not supported by sufficient evidence, and that his

conviction on Count 1 for being a felon in possession of a firearm is invalid based on Rehaif

v. United States, 139 S. Ct. 2191 (2019). For the following reasons, we affirm.

First, Littlejohn argues that he was entitled to a Franks hearing because law

enforcement made false statements in the affidavit used to obtain a search warrant for his

residence and the four vehicles on the property. We review de novo a district court’s legal

determination whether a defendant “provided enough evidence to be entitled to a Franks

hearing.” United States v. Haas, 986 F.3d 467, 474 (4th Cir.), cert. denied, 142 S. Ct. 292

(2021). We review for clear error factual findings related to legal determinations. United

States v. Jones, 942 F.3d 634, 640 (4th Cir. 2019). Franks hearings provide criminal

defendants “a narrow way to attack the validity of a search-warrant affidavit” in order to

∗ Franks v. Delaware, 438 U.S. 154 (1978).

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protect against the use of “affirmative false statements” in the affidavit. Haas, 986 F.3d at

474 (internal quotation marks omitted). To do so, however, defendants must “overcome

the presumption of validity” afforded the affidavit supporting the search warrant. Id.

(internal quotation marks omitted). To obtain a Franks hearing, Littlejohn “must make a

substantial preliminary showing that (1) law enforcement made a false statement; (2) the

false statement was made knowingly and intentionally, or with reckless disregard for the

truth; and (3) the false statement was necessary to the finding of probable cause.” United

States v. Moody, 931 F.3d 366, 370 (4th Cir. 2019) (internal quotation marks omitted). We

conclude that Littlejohn failed to make the required substantial preliminary showing,

instead relying only on conclusory allegations of falsity. Therefore, we conclude that the

district court did not err by denying his request for a Franks hearing and denying his motion

to suppress.

Next, Littlejohn asserts that the district court erred in admitting the testimony of a

witness who testified that Littlejohn had discharged a firearm on a prior occasion. We

review a trial court’s rulings on the admissibility of evidence for abuse of discretion,

viewing the “evidence in the light most favorable to the proponent[ and] maximizing its

probative value and minimizing its prejudicial effect.” Burgess v. Goldstein, 997 F.3d 541,

559 (4th Cir. 2021) (internal quotation marks omitted). Thus, “[w]e will overturn an

evidentiary ruling only if it is arbitrary and irrational.” Id. Moreover, we will not overturn

a conviction due to an erroneous evidentiary ruling if the error is harmless—that is, if “we

can say with fair assurance, after pondering all that happened without stripping the

erroneous action from the whole, that the judgment was not substantially swayed by the

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error.” Id. at 561 (internal quotation marks omitted). Here, even if the district court erred

in admitting the challenged testimony, we conclude that any error was harmless.

Therefore, we decline to overturn Littlejohn’s conviction on this ground.

Littlejohn further contends that the court erroneously instructed the jury on the

meaning of the phrase “on or about” in the indictment. We generally “review a district

court’s decision to give a particular jury instruction for abuse of discretion, and review

whether a jury instruction incorrectly stated the law de novo.” United States v. Hassler,

992 F.3d 243, 246 (4th Cir. 2021) (internal quotation marks omitted). Because Littlejohn

did not object to the jury instruction at trial, however, our review is for plain error. See

United States v. Ali, 991 F.3d 561, 572 (4th Cir.), cert. denied, 142 S. Ct. 486 (2021). On

plain error review, Littlejohn must establish “(1) that the court erred, (2) that the error is

clear and obvious, . . . (3) that the error affected his substantial rights,” and that the error

“seriously affects the fairness, integrity[,] or public reputation of judicial proceedings.” Id.

(internal quotation marks omitted). Littlejohn has failed to establish that the district court

committed a clear and obvious error in its jury instructions.

Littlejohn also argues that insufficient evidence supports his conviction on Count 3,

asserting that the Government failed to prove he possessed the firearm “in furtherance of”

a drug trafficking offense. We review de novo a district court’s denial of a motion for a

judgment of acquittal based on the sufficiency of the evidence. United States v. Farrell,

921 F.3d 116, 136 (4th Cir. 2019). “A jury’s guilty verdict must be upheld if, viewing the

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Related

Franks v. Delaware
438 U.S. 154 (Supreme Court, 1978)
United States v. Clarence J. Lomax
293 F.3d 701 (Fourth Circuit, 2002)
United States v. James Michael Farrell
921 F.3d 116 (Fourth Circuit, 2019)
Rehaif v. United States
588 U.S. 225 (Supreme Court, 2019)
United States v. Benitez Moody
931 F.3d 366 (Fourth Circuit, 2019)
United States v. Gary Jones
942 F.3d 634 (Fourth Circuit, 2019)
United States v. Richard Haas
986 F.3d 467 (Fourth Circuit, 2021)
United States v. Hassan Ali
991 F.3d 561 (Fourth Circuit, 2021)
United States v. Gary Hassler
992 F.3d 243 (Fourth Circuit, 2021)
Sabein Burgess v. Gerald Goldstein
997 F.3d 541 (Fourth Circuit, 2021)
Greer v. United States
593 U.S. 503 (Supreme Court, 2021)
United States v. Joseph Ziegler
1 F.4th 219 (Fourth Circuit, 2021)
United States v. Anthony Caldwell
7 F.4th 191 (Fourth Circuit, 2021)

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United States v. Quinton Littlejohn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-quinton-littlejohn-ca4-2023.