Roosevelt Whitfield v. United States
2014 D.C. App. LEXIS 380
| D.C. | 2014Background
- Appellant Roosevelt Whitfield, an off-duty bank security guard and Air Force member, was stopped after police observed his Texas rear license plate frame obscured the plate motto “Lone Star State”; the issuing jurisdiction and alphanumeric characters remained legible.
- During the stop officers saw a holster in plain view, Whitfield initially denied a gun, later admitted to a .38 in the car; officers recovered a loaded revolver and ammunition and arrested him.
- Whitfield moved to suppress the gun and ammo, arguing the traffic stop lacked reasonable suspicion because the frame did not violate 18 DCMR § 422; he also moved to dismiss on Second Amendment grounds (as-applied challenge to D.C. carry/registration laws).
- Trial court denied suppression, concluding §§ 422.5 and 422.6 prohibit non-transparent attachments and any obstruction of “any part” of the tag; Whitfield conditionally pleaded guilty and appealed the suppression and constitutional rulings.
- The D.C. Court of Appeals reversed the denial of suppression, holding the municipal regulations ambiguous as to whether non-identifying parts of a plate (e.g., state motto) are protected and applying the rule of lenity to resolve ambiguity for the defendant.
- Because the stop was unlawful, the court suppressed the evidence and reversed the convictions; it did not reach the Second Amendment question.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of traffic stop under 18 DCMR § 422 (license plate frame) | Whitfield: § 422 only prohibits obstruction of identifying information (numbers/letters, issuing jurisdiction, registration stickers); his frame only covered state motto and did not violate the rule. | Government: § 422.5 forbids any non-transparent foreign material on the tag; § 422.6 bars any emblem over 24 sq in or that obstructs any part of the tag — so the frame violated the regulations. | Court: §§ 422.5 and 422.6 are ambiguous; read in context they reasonably apply only to obstruction of identifying information. Applying rule of lenity, police lacked lawful basis to stop Whitfield; suppression required. |
| Second Amendment as-applied challenge to D.C. carry/registration laws | Whitfield: D.C. laws effectively ban nonresident, law‑abiding persons from carrying handguns for self-defense outside the home. | Government: D.C. allows possession outside the home in limited circumstances and has regulatory scheme; stop was lawful. | Court: Did not decide because suppression ruling was dispositive. |
Key Cases Cited
- Bennett v. United States, 26 A.3d 745 (D.C. 2011) (standard for reviewing suppression rulings)
- Watson v. United States, 43 A.3d 276 (D.C. 2012) (defer to trial court factual findings; legal conclusions reviewed de novo)
- United States v. McDonald, 453 F.3d 958 (7th Cir. 2006) (an officer’s mistake of law cannot supply reasonable suspicion/probable cause)
- Belay v. District of Columbia, 860 A.2d 365 (D.C. 2004) (rule of lenity applies to criminal statutes and ambiguities are resolved for defendant)
- United States v. Thompson/Center Arms Co., 504 U.S. 505 (U.S. 1992) (rule of lenity applied in civil context where statute had criminal applications)