United States v. Robert Whitfield

CourtCourt of Appeals for the Third Circuit
DecidedJune 30, 2022
Docket20-3634
StatusUnpublished

This text of United States v. Robert Whitfield (United States v. Robert Whitfield) 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. Robert Whitfield, (3d Cir. 2022).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 20-3634 _____________

UNITED STATES OF AMERICA

v.

ROBERT LAMAR WHITFIELD a/k/a Lamar Whitfield a/k/a Goat, Appellant _____________

On Appeal from the United States District Court for the Eastern District of Pennsylvania (D.C. No. 2-12-cr-00418-001) Chief District Judge: Honorable Juan R. Sanchez _____________

Argued: June 8, 2022 _____________

Before: CHAGARES, Chief Judge, AMBRO, and FUENTES, Circuit Judges.

(Filed: June 30, 2022)

Saumya Vaishampayan, Student Counsel [ARGUED] Alexis Karteron Rutgers University School of Law 123 Washington Street Newark, NJ 07102

Counsel for Appellant

Robert A. Zauzmer [ARGUED] Office of United States Attorney 615 Chestnut Street Suite 1250 Philadelphia, PA 19106

Counsel for Appellee

_____________________

OPINION _____________________

CHAGARES, Chief Judge.

Robert Lamar Whitfield appeals the District Court’s order denying his 28 U.S.C.

§ 2255 motion. Whitfield contends that his trial counsel provided ineffective assistance

of counsel by submitting an untimely motion for discovery on a selective enforcement

claim. For the following reasons, we will affirm the judgment of the District Court.

I.

We write primarily for the parties and recite only the facts essential to our

decision. This case began with a “reverse sting,” an investigative technique used by the

Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF”). A reverse sting occurs

when an undercover ATF agent or a confidential informant “pose[s] as a drug courier

looking to recruit a team to rob a . . . drug stash house of which he ha[s] inside

knowledge.” Appendix (“App.”) 99. But there is no stash house to rob; it is imaginary.

In May 2012, the ATF began investigating a man named Kwasi Payne and decided

to target him for a reverse sting. After experiencing difficulties keeping in contact with

 This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent.

2 Payne, a confidential informant (“CI”) contacted Whitfield and explained that he was

trying to get in touch with Payne about a “situation” (a robbery). App. 100. Whitfield

expressed interest in the robbery, and the ATF shifted its reverse sting to him. An

undercover ATF agent and the CI met with Whitfield and described a fake stash house to

which they had access. Whitfield then recruited an eight-person crew to help him rob the

stash house. An ATF response team arrested the entire crew on the morning of the

planned robbery.

The crew members were charged with several counts of conspiracy to commit

robbery, conspiracy to possess drugs with intent to distribute, attempted robbery,

attempted possession with intent to distribute, and carrying a firearm during and in

relation to a crime of violence/drug trafficking crime. Whitfield proceeded to trial in

May 2013 and was found guilty of five counts. In June 2013, USA Today ran an article

criticizing the ATF’s reverse sting operations, and in August 2013, it reported that the

Chief Judge of the United States District Court for the Northern District of Illinois had

granted discovery for a selective enforcement claim1 based on a “strong showing of

potential bias” in the use of reverse stings for fake stash house robberies. App. 102.

In October 2013 –– months after Whitfield’s trial –– Whitfield’s trial counsel, J.

Michael Farrell, filed a motion for a hearing and for discovery on the issue of racial

1 Selective enforcement “occurs when police investigate people of one race but not similarly-situated people of a different race.” Conley v. United States, 5 F.4th 781, 789 (7th Cir. 2021).

3 profiling and selective prosecution.2 The motion argued that the ATF and the United

States Attorney’s Office targeted African Americans and Latinos in its reverse sting

operations. The District Court held a hearing on the motion and questioned Farrell about

why he filed the motion months after Whitfield’s trial. Farrell explained that it was only

after seeing the USA Today articles that he began investigating the issue.

The District Court denied the motion, holding that the defendants had “not shown

good cause for their failure to pursue this issue prior to trial.” App. 107. The court also

held that even if the defendants had shown good cause, they had not made the threshold

showing necessary for obtaining discovery. The court relied on United States v.

Armstrong, 517 U.S. 456 (1996), which held that to obtain discovery on a claim of

selective prosecution, the claimant must make a prima facie showing by providing “some

evidence tending to show the existence of the essential elements of the defense,

discriminatory effect and discriminatory intent,” including “a credible showing of

different treatment of similarly situated persons.” Id. at 468, 470 (cleaned up). The

District Court applied this standard to Whitfield’s request for discovery on his selective

prosecution and enforcement claims and held that he had not made a showing of different

treatment of similarly situated individuals of another race.

2 The defense initially labeled this motion as seeking discovery for a selective prosecution claim. But, as the District Court noted, “[d]efendants’ allegations of racial bias concern not only the decision to prosecute them but also the decision to target them in an ATF sting operation.” App. 106 n.7. The District Court therefore “underst[ood] them to be raising a potential claim of selective enforcement as well as a claim of selective prosecution.” Id. (emphasis added).

4 Whitfield appealed the District Court’s denial of discovery. This Court affirmed

the judgment of the District Court, holding that Whitfield forfeited his selective

enforcement claim because “[c]laims or defenses based on a ‘defect in instituting the

prosecution’ must be raised before trial.” United States v. Whitfield, 649 F. App’x 192,

196 (3d Cir. 2016) (quoting Fed. R. Crim. P. 12(b)(3)(A)). The Court did not reach the

merits of Whitfield’s request, but it noted that the Armstrong standard created an

“effectively insurmountable” hurdle for defendants seeking discovery on selective

enforcement claims. Id. at 196 n.11. The Court cited a recent United States Court of

Appeals for the Seventh Circuit decision involving a reverse sting in which the court held

that Armstrong did not apply to discovery requests related to selective enforcement

claims. Id. (citing United States v. Davis, 793 F.3d 712 (7th Cir.2015) (en banc)). But

because Whitfield forfeited his claim, the Court saved the question of “[w]hether or not

the court in Davis was correct that Armstrong should not apply to selective enforcement

claims . . . for another day.” Id.

That day came in August 2017, when the Court in United States v. Washington,

869 F.3d 193 (3d Cir. 2017) followed the Seventh Circuit and held that “putative claims

of unconstitutional selective enforcement are not governed by strict application of the

Armstrong[] framework.” Id. at 220.

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