United States v. Alston
626 F.3d 397
| 8th Cir. | 2010Background
- Alston, on parole for narcotics offenses, agreed to conditions including no association with felons and warrantless searches of person, residence, and vehicle.
- Oteri, a parolee, was suspected of drug distribution; after fleeing, he was detained and found with methamphetamine and cash.
- Oteri implicated a dealer 'DA' in room 416; officers identified Alston as the most likely 'DA' and approached the hotel.
- Alston exited the hotel during questioning; officers detained him for suspected parole violation and searched him, finding currency.
- Angela Groves allowed a room 416 search; cocaine and cocaine base were found, and Groves claimed the drugs belonged to Alston.
- At police department, Napier advised Miranda rights and took notes of Alston’s confession; defense challenged cross-examination limiting Napier’s credibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether detention/search were supported by reasonable suspicion | Alston | Alston | Reasonable suspicion existed; evidence supports detention and search. |
| Whether cross-examination of Napier was properly limited under Rule 608(b) | Alston | Alston | No reversible error; district court’s limitation was within discretion. |
| Whether the $5,000 fine was properly imposed given payability considerations | Alston | Alston | No plain error; district court considered ability to pay with installment plan. |
| Whether life sentence based on judicial findings of prior convictions violates the Sixth Amendment | Alston | Alston | Foreclosed by Almendarez-Torres and Sherman precedent; constitutional. |
Key Cases Cited
- Ornelas v. United States, 517 U.S. 690 (1996) (reasonable-suspicion standard applies to vehicle/stops)
- United States v. Nichols, 574 F.3d 633 (8th Cir. 2009) (de novo review of suppression, with factual findings reviewed for clear error)
- King v. Ahrens, 16 F.3d 265 (8th Cir. 1994) (Rule 608(b) balancing of probative value and prejudice; avoiding mini-trials)
- McClintic, 570 F.2d 685 (8th Cir. 1978) (admissibility of specific misconduct on cross-examination per Rule 608(b))
- Fulminante, 499 U.S. 279 (1991) (confessions' impact on juries and the limits of cross-examination)
- DeLuna, 763 F.2d 897 (8th Cir. 1985) (Rule 608(b) deference to district court findings on admissibility)
- Vaughn, 519 F.3d 802 (8th Cir. 2008) (plain-error standard for sentencing proportionality and a defendant's burden)
- Almendarez-Torres v. United States, 523 U.S. 224 (1998) (prior convictions adopted for sentencing fall under due-process precedent)
- Sherman v. United States, 440 F.3d 982 (8th Cir. 2006) (prior-conviction facts established for sentencing)
- Hines v. United States, 88 F.3d 661 (8th Cir. 1996) (distinguishing reasoning on dependants and fines in sentencing)
- Novaton v. Atlantic, 271 F.3d 968 (11th Cir. 2001) (danger of unfair prejudice from prior misconduct testimony)
- Whitmore v. United States, 359 F.3d 609 (D.C. Cir. 2004) (distinguishing circumstances for cross-examination limits)
- United States v. Beck, 557 F.3d 619 (8th Cir.) (abuse of discretion standard for cross-examination limits)