United States v. Casahonda, 4:17-cr-01904

Defendant Edgar Antonio Casahonda filed a Motion for Reconsideration of the court's November 3, 2021 Order; no response was filed.
The Court framed the reconsideration standard under Rule 59(e) and Rule 60(b) and noted such motions are granted only in rare circumstances.
Casahonda principally objected to factual summaries under the heading "Testimony of Chad Sutterley," arguing some descriptions misstate the agent's testimony.
The Court found the contested summary generally reflected Sutterley’s testimony and denied reconsideration on that basis.
The Court agreed one specific statement (that the agent ‘‘had a copy of Casahonda’s Arizona driver’s license photo from a previous investigation’’) misstated testimony but concluded the agent had been told Casahonda’s name from a February 2016 referral and could have obtained a DL photo—so the error did not undermine the independent-source finding.
The Court also held that, while ATF policy about observing four firearms loaded into a vehicle does not alone justify a stop, the implicated vehicle had prior association with trafficking incidents, supporting an independent-source rationale; the Motion for Reconsideration was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether reconsideration is warranted under Rule 59(e)/60(b) for alleged factual errors	Reconsideration standards not met; prior findings stand	Order mischaracterizes agent testimony and factual findings	Denied — mere disagreement and alleged misstatements do not justify reconsideration
Whether the statement that the agent had a prior copy of Casahonda’s DL photo invalidates the independent-source finding	Even if mischaracterized, agent knew Casahonda’s name from a Feb 2016 referral and could obtain DL photo; independent source remains	The statement is inaccurate and material to credibility of the summary	Court agrees the statement was inaccurate but finds the error immaterial to the independent-source conclusion
Whether ATF policy about seeing four firearms being loaded justifies a stop or supports independent-source evidence	Vehicle had prior ties to trafficking; Sutterley would open a trafficking investigation — an independent source exists	Policy alone does not constitutionally justify a traffic stop	Court: policy alone insufficient for Fourth Amendment stop, but vehicle’s prior association with trafficking supports independent-source finding; motion denied

School Dist. No. 1J, Multnomah County v. ACandS, Inc., 5 F.3d 1255 (9th Cir. 1993) (standards for reconsideration under Rule 59(e) and Rule 60(b))
Fuller v. M.G. Jewelry, 950 F.2d 1437 (9th Cir. 1991) (grounds for relief under Rule 60(b))
Backlund v. Barnhart, 778 F.2d 1386 (9th Cir. 1985) (Rule 60(b) framework)
Defenders of Wildlife v. Browner, 909 F. Supp. 1342 (D. Ariz. 1995) (motions for reconsideration are granted only in rare circumstances)
Above the Belt, Inc. v. Mel Bohannan Roofing, Inc., 99 F.R.D. 99 (E.D. Va. 1983) (motions for reconsideration are not for rehashing prior rulings)