United States v. Arthur Santiful, 701 F. App'x 242

Arthur D. Santiful was convicted by a jury of conspiracy and ten robberies (Hobbs Act/§1951), two §924(c) firearm counts (brandishing and discharging), and being a felon in possession of a firearm (§922(g)(1)).
Santiful moved to suppress statements from a custodial post-arrest interview, arguing his ambiguous request for counsel required cessation under Miranda.
The government introduced testimony that Santiful had taken a Hi‑Point .45 from a former girlfriend—same make used in the charged robberies—to link him to the weapon.
Santiful challenged admission of that prior-act evidence under Fed. R. Evid. 404(b) and contested the sufficiency of the evidence as to two 7‑Eleven robbery counts.
The district court denied suppression, admitted the prior-act testimony with a limiting instruction, and the jury convicted; Santiful appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether post‑arrest statements should be suppressed because Santiful invoked right to counsel	Santiful: his question (“Gotta a lawyer here right now?”) amounted to invocation requiring end of questioning	Government: his question was ambiguous/equivocal; he was told counsel unavailable and then agreed to proceed	Court: Question was not a clear, unambiguous request for counsel; denial of suppression affirmed
Whether testimony that Santiful took a Hi‑Point .45 from a former girlfriend was inadmissible prior‑bad‑acts evidence under Rule 404(b)	Santiful: evidence was improper propensity evidence and unduly prejudicial	Government: evidence relevant to identity, necessary and reliable; intrinsic or admissible 404(b) evidence; limiting instruction mitigated prejudice	Court: Evidence admissible as probative on identity, reliable, not unduly prejudicial; admission within district court’s discretion
Whether evidence was insufficient to sustain convictions for two 7‑Eleven robberies	Santiful: argues government failed to prove his participation beyond reasonable doubt (attacks co‑defendant’s credibility)	Government: surveillance videos plus co‑defendant Zeigler’s identification and other evidence support convictions	Court: Viewing evidence in government’s favor, jury could reasonably convict; sufficiency challenge fails

Davis v. United States, 512 U.S. 452 (1994) (clarifies that invocation of right to counsel must be clear and unambiguous)
United States v. Gardner, 823 F.3d 793 (4th Cir. 2016) (standard of review for suppression: legal questions de novo, factual findings for clear error)
United States v. Siegel, 536 F.3d 306 (4th Cir. 2008) (Rule 404(b) admissibility: relevance, necessity, reliability, and prejudice balancing)
United States v. Rooks, 596 F.3d 204 (4th Cir. 2010) (evidence need not be critical to be “necessary” under Rule 404(b) if probative of an element)
United States v. Burgos, 94 F.3d 849 (4th Cir. 1996) (en banc) (standard for sufficiency review: substantial evidence construed in government’s favor)
United States v. Cole, 631 F.3d 146 (4th Cir. 2011) (district court evidentiary rulings reviewed for abuse of discretion)