Jamel Evans v. United States, 122 A.3d 876

Evans challenges his convictions for attempted possession of unregistered firearms and attempted unlawful possession of ammunition, arguing Fourth Amendment suppression and sufficiency issues.
In April 2013, Evans called 911 about a domestic-violence incident; at the scene, Evans and Shantay Taylor gave conflicting accounts with no third-party involvement indicated.
Officer Wendt entered the apartment without a warrant after observing blood and other indicators, with other officers already interviewing Evans and Taylor.
During a room-by-room search, officers found a gun in an open closet in one bedroom and a .38-caliber round on a dresser; later, a 16-gauge shotgun, a .22 rifle, and additional ammunition were found in the two bedrooms, along with other items (clothes, jacket, pill bottle, summons, etc.).
The trial court convicted Evans on the gun and ammunition counts but acquitted related marijuana and other ammunition; the appellate court reversed due to suppression of evidence from the unlawful entry, and remanded for further proceedings, while addressing sufficiency of the remaining construct possession theory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Officer Wendt's warrantless entry was lawful	Evans contends entry violated the Fourth Amendment	United States asserts emergency-aid basis	Entry not supported by emergency-aid; suppress evidence
Whether suppression of the evidence is required	Suppression appropriate due to unlawful entry	Evidence could be admitted under exceptions or good-faith	Suppression required; taint not attenuated; convictions reversed
Whether the evidence is sufficient to prove constructive possession beyond a reasonable doubt	Evans’s residency and proximity to contraband supports possession	Shared occupancy and weak links to second-item undermine possession	Evidence sufficient to support convictions for possession in the first bedroom; issue as to second gun rejected by the majority

Brigham City v. Stuart, 547 U.S. 398 (U.S. 2006) (emergency-aid exception requires a reasonable basis for emergency entry)
United States v. Booth, 455 A.2d 1351 (D.C. 1983) (probable cause standard for immediate-entry emergencies)
Murray v. United States, 487 U.S. 533 (U.S. 1988) (independent-source doctrine to avoid taint from unlawful entry)
Smith v. United States, 111 A.3d 1 (D.C. 2014) (arrest-warrant based on illegally obtained evidence cannot cure taint; suppression applied)
Schools v. United States, 84 A.3d 503 (D.C. 2013) (constructive possession requires fact-specific inquiry; proximity and personal items weigh)