Johnson v. United States
40 A.3d 1
D.C.2012Background
- Johnson was convicted of misdemeanor PWID after two felony trials ended in hung juries; controlled delivery of a marijuana parcel led to arrest.
- Parcel from Ricardo Austin contained ~4,797 grams of marijuana; delivery to Corey Johnson at an address not tied to him; Johnson's girlfriend's address used.
- Johnson signed a receipt and identified himself as Corey Johnson, though he later testified he was Courtney Johnson.
- Officers seized the parcel from Johnson’s car and conducted a search incident to arrest; they collected corroborating documents.
- A California-based investigation paralleled the D.C. delivery, tying Johnson to a larger drug-distribution scheme.
- Johnson moved to suppress evidence and statements; suppression motions were denied; bench trial convicted him.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to arrest after controlled delivery | Johnson lacked probable cause | Police had probable cause from controlled delivery | Probable cause established based on totality of circumstances |
| Admissibility of post-arrest statement under Miranda | Statement obtained in custody without Miranda warnings | Statement was not elicited via custodial interrogation | Miranda not violated; statement admissible |
| Sufficiency of evidence for possession with intent to distribute | Insufficient proof of possession and intent | Evidence supported possession and distribution intent | Evidence sufficient; conviction affirmed |
Key Cases Cited
- Illinois v. Andreas, 463 U.S. 765 (U.S. Supreme Court 1983) (controlled delivery rationale; lawful interception of contraband)
- Ornelas v. United States, 517 U.S. 690 (U.S. Supreme Court 1996) (probable cause review standard; totality of the circumstances)
- Dawkins v. United States, 987 A.2d 470 (D.C. 2010) (search incident to arrest and Chimel/Thornton framework)
- United States v. Gant, 556 U.S. 332 (U.S. Supreme Court 2009) (scope of vehicle searches incident to arrest)
- Criminal v. Thornton, 541 U.S. 615 (U.S. Supreme Court 2004) (authority for search of vehicle incident to arrest)