United States v. Vincent Carnelius Eura, United States of America v. Vincent Carnelius Eura

440 F.3d 625, 2006 WL 440099
CourtCourt of Appeals for the Fourth Circuit
DecidedFebruary 24, 2006
Docket05-4437, 05-4533
StatusPublished
Cited by154 cases

This text of 440 F.3d 625 (United States v. Vincent Carnelius Eura, United States of America v. Vincent Carnelius Eura) 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. Vincent Carnelius Eura, United States of America v. Vincent Carnelius Eura, 440 F.3d 625, 2006 WL 440099 (4th Cir. 2006).

Opinions

Affirmed in part, vacated in part, and remanded by published opinion. Senior Judge HAMILTON wrote the opinion, in which Judge WILKINSON joined. Judge MICHAEL wrote a separate opinion concurring in the judgment and concurring in part.

OPINION

HAMILTON, Senior Circuit Judge:

Under the United States Sentencing Guidelines, a defendant who deals five grams of crack cocaine faces the same sentence as a defendant who deals five hundred grams of powder cocaine. This disparity is commonly referred to as the “100:1 ratio.” Congress adopted the 100:1 crack cocaine/powder cocaine ratio in 1986, thereby setting mandatory minimum sentences based on the quantity of cocaine, in crack or powder form.1 In 1987, the Sentencing Commission, following Congress’ lead, adopted the same ratio, when it fashioned the Drug Quantity Table found at USSG § 2Dl.l(c). Under the Guidelines, the Drug Quantity Table determines a defendant’s offense level, which ultimately controls the sentencing range under the Guidelines. In 1995, 1997, and most recently in 2002, Congress declined to entertain the Commission’s entreaties to narrow the ratio.

In United States v. Booker, 543 U.S. 220, 125 S.Ct. 738, 160 L.Ed.2d 621 (2005), the Supreme Court held that the mandatory Guidelines scheme providing for sentence enhancements based on facts found by the sentencing court violated the Sixth Amendment. Id. at 755-56 (Stevens, J., opinion for the Court). The Court remedied the constitutional violation by severing and excising the statutory provisions which mandated sentencing and appellate review under the Guidelines, thus making the Guidelines advisory. Id. at 756-57 (Breyer, J., opinion for the Court).

The principal question presented in this appeal is whether a district court in the post-Booker world can vary from the advisory sentencing range under the Guidelines by substituting its own crack cocaine/powder cocaine ratio for the 100:1 crack cocaine/powder cocaine ratio chosen by Congress. For the reasons stated below, we conclude a court cannot vary from the sentencing range in' such a manner.

I

A

On May 3, 2004, agents of the Drug Enforcement Administration (DEA) ap[628]*628plied for and obtained a search warrant for 353 Riverside Manor Boulevard in Freder-icksburg, Virginia. The search warrant application in large part was based on information provided by a cooperating source. The source, whose information had led to the arrest of at least one other drug trafficker, told the agents that he had been buying crack cocaine from Vincent Eura since 1996 and had purchased crack cocaine from him as recently as March 2004.2 Most of these purchases had occurred at Eura’s residence. In a recorded telephone conversation on May 3, 2004, the source asked Eura if he had any crack cocaine and Eura responded that he was “straight.” (J.A. 28). According to the source, Eura had used the term “straight” in the past to indicate that he had crack cocaine to sell. (J.A. 28). In a later conversation, the source and Eura arranged to meet that evening at Eura’s residence.

Rather than allowing the source to buy crack cocaine from Eura, the DEA agents obtained and executed a search warrant for Eura’s home. The search occurred at approximately 9:30 p.m. on May 3, 2004. During the search, Eura was detained and placed in handcuffs for officer safety.

The . search of Eura’s home yielded several automatic weapons but no drugs. Eura told the agents that the weapons were his. An unidentified woman at the residence told the DEA agents that a BMW and a Mitsubishi Diamante parked on the street belonged to Eura. A license plate check with the Virginia Department of Motor Vehicles (DMV) verified that the two automobiles were registered to Eura.

Special Agent William Harding testified that he spoke with Eura about the automobiles and asked for consent to search them. Eura refused. Agent Harding then asked a local K-9 unit to walk around the two automobiles.

A drug detection dog alerted to Eura’s Mitsubishi Diamante, indicating the presence of drugs. The DEA agents then opened the automobile and the dog alerted to the center console area. With the help of the dog, the agents recovered eleven grams of crack cocaine and 26.6 grams of MDA (ecstacy) from the center console armrest. A further search of the automobile resulted in the discovery of a loaded firearm in the glove compartment.

B

On July 19, 2004, Eura was charged in a three-count second superseding indictment with conspiring to possess with intent to distribute fifty grams or more of crack cocaine, 21 U.S.C. §§ 841(b)(1)(A) and 846 (Count One), possession with intent to distribute five grams or more of crack cocaine, 21 U.S.C. §§ 841(a)(1) and (b)(1)(B) (Count Two), and possession of a firearm in furtherance of a drug trafficking crime, 18 U.S.C. § 924(c) (Count Three).

Prior to trial, Eura moved to suppress the evidence obtained during the warrant-less search of his Mitsubishi Diamante. The district court denied the motion.

Following a trial, Eura was convicted on Counts Two and Three, but acquitted on Count One. The jury found that Eura’s conviction on Count Two involved between five and twenty grams of crack cocaine. On April 15, 2005, he was sentenced to 120 months’ imprisonment, consisting of a sixty-month sentence on Count Two and a sixty-month consecutive sentence on Count Three. Eura noted a timely appeal, challenging his convictions. The government filed a timely cross-appeal, challenging Eura’s sentence.

[629]*629II

In his appeal, Eura contends that the warrantless search of his Mitsubishi Diamante violated his rights guaranteed by the Fourth Amendment. More specifically, Eura contends that, while the search of his home was permissible pursuant to the search warrant, once the DEA agents found no drugs in his home, the subsequent K-9 sniff of his automobiles was not permissible under the Fourth Amendment.

The Fourth Amendment guarantees “[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures.” U.S. Const. amend. IV. A K-9 sniff is not a search within the meaning of the Fourth Amendment and, thus, neither probable cause nor a warrant is required. United States v. Place, 462 U.S. 696, 706-07, 103 S.Ct. 2637, 77 L.Ed.2d 110 (1983). However, “[rjeasonable suspicion” is required for the temporary seizure of the vehicle and any occupants that are necessary to facilitate a K-9 sniff of the exterior of a vehicle. United States v. Foreman, 369 F.3d 776, 781 (4th Cir.2004).

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Bluebook (online)
440 F.3d 625, 2006 WL 440099, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-vincent-carnelius-eura-united-states-of-america-v-ca4-2006.