Hampleton v. United States
10 A.3d 137
D.C.2010Background
- On May 11, 2006, five robbers in a stolen black Jeep Liberty gunpoint robbed three men and fled; victims alerted police.
- Police broadcast lookout for five or six black males in dark clothing in a black Jeep with Virginia tags; Jeep crashed and suspects fled toward Archbishop Carroll High School.
- Officer Neffon observed suspects near the school; Officer Antoine spotted Casey Hampleton about 10–15 minutes after bailout and stopped him on North Capitol Street.
- Hampleton was handcuffed and frisked; officers found four cell phones and a cash card on him, later linked to the victims.
- Eng, Ford, and Kastronis identified Hampleton as a robber; an earlier suppression ruling suppressed the cell phones and cash card; other stop-related evidence admitted.
- Hampleton was convicted on multiple armed-robbery and firearms charges; he argued show-up identifications and certain physical evidence were fruits of an illegal seizure and PFCV counts should merge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonable suspicion for stop | Hampleton: lack of particularized suspicion from vague lookout | United States: totality of circumstances supports stop | Stop supported by reasonable articulable suspicion |
| Suppression of cell phones and cash card | Papers: fruits of unlawful frisk | frisk doctrine did not justify suppression of all items | Cell phones and cash card suppressed as beyond frisk scope |
| Admissibility of show-up identifications | Identifications tainted by illegal seizure | identifications independent of seizure | Show-ups and related physical evidence admissible |
| Merge of PFCV convictions | Three PFCV counts based on different victims do not merge | PFCV convictions merge under fresh-impulse/fork-in-the-road test | PFCV convictions merge; remand to vacate two counts |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (U.S. Supreme Court 1996) (framework for reviewing suppression findings under totality of circumstances)
- Turner v. United States, 699 A.2d 1125 (D.C. 1997) (totality-of-circumstances approach to reasonable suspicion)
- In re A.S., 614 A.2d 534 (D.C. 1992) (vague lookouts and specificity required; dragnet concerns noted)
- In re T.L.L., 729 A.2d 334 (D.C. 1999) (limited individualization matters for stop under vague description)
- United States v. Cortez, 449 U.S. 411 (U.S. Supreme Court 1981) (framework for reasonable suspicion based on totality of circumstances)
- Matthews v. United States, 892 A.2d 1100 (D.C. 2006) (fresh impulse/fork-in-the-road doctrine for PFCV merger)
- Nixon v. United States, 730 A.2d 145 (D.C. 1999) (PFCV merger principle reaffirmed)
- Tetaz v. District of Columbia, 976 A.2d 907 (D.C. 2009) (collective knowledge doctrine in fast-moving police investigations)
- Smart v. United States, 98 F.3d 1379 (D.C. Cir. 1996) (lookout-based stop upheld when defendant uniquely matches description)