United States v. Alfredo Ramirez
669 F. App'x 163
| 4th Cir. | 2016Background
- In Oct. 2014 a federal grand jury charged Alfredo de Jesus Ramirez with conspiracy to distribute and possess with intent to distribute methamphetamine (thresholds triggering § 841(b)(1)(A)).
- A 2-day jury trial with 13 witnesses resulted in Ramirez’s conviction; district court sentenced him to 292 months’ imprisonment.
- Ramirez moved pretrial to suppress evidence from a Feb. 2013 Tennessee traffic stop: testimony of Deputy Scott Baker, $20,000 cash, a small quantity of methamphetamine, and Ramirez’s post-seizure statement.
- At the suppression hearing the court watched the stop video, heard Baker’s testimony, and denied the motion to suppress.
- On appeal Ramirez argued the stop became an unlawful prolonged detention under United States v. Digiovanni; he sought exclusion of Baker’s testimony and the seized items/statements.
- The Fourth Circuit assumed, for purposes of decision, that the denial might be erroneous but held any error harmless because the Government’s other direct and circumstantial evidence independently supported the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence from the Feb. 2013 traffic stop should have been suppressed because the detention exceeded its permissible scope | Ramirez: detention lasted longer than necessary under Digiovanni; evidence and statements should be suppressed | Government: even if suppression was warranted, the challenged evidence was cumulative and not necessary to proof; conviction supported by other strong evidence | Even if the stop denial was erroneous, the error was harmless beyond a reasonable doubt — conviction affirmed |
Key Cases Cited
- United States v. Digiovanni, 650 F.3d 498 (4th Cir. 2011) (defines limits on lawfully prolonged traffic stops)
- United States v. Green, 599 F.3d 360 (4th Cir. 2010) (standard of review for suppression rulings: factual findings for clear error; legal conclusions de novo)
- United States v. Poole, 640 F.3d 114 (4th Cir. 2011) (harmless error standard: conviction stands if rational factfinder would convict absent the error)
- United States v. Blauvelt, 638 F.3d 281 (4th Cir. 2011) (suppression rulings subject to harmless-error analysis)
- United States v. Abu Ali, 528 F.3d 210 (4th Cir. 2008) (discusses appellate review scope for suppression decisions)
- Chapman v. California, 386 U.S. 18 (U.S. 1967) (harmless beyond a reasonable doubt standard)