United States v. Chambers
681 F. App'x 72
| 2d Cir. | 2017Background
- Chambers was convicted by a jury of Hobbs Act robbery (conspiracy and substantive) and federal kidnapping, and sentenced to 20 years' imprisonment; appeal from S.D.N.Y. judgment affirmed.
- Victim Emma Torruella identified Chambers at trial but later recanted parts of her testimony; Torruella’s daughter Demi Torres made pretrial identifications that were later struck at trial.
- Circumstantial evidence included phone records linking a phone labeled “Twizie” to Brown and to locations near Brown’s apartment, a license-plate partial matching a car registered to Chambers’s girlfriend, a hammer found in that car consistent with victim testimony, flight/consciousness-of-guilt evidence, and false ID given by Chambers at arrest.
- The government used § 2703(d) SCA orders to obtain cell-site location information for the Twizie phone.
- Chambers raised multiple challenges on appeal: sufficiency of evidence, admission of identification testimony, Brady nondisclosure, admissibility/adequacy of SCA authorization, and constitutional challenges to 18 U.S.C. § 1201 (kidnapping statute) under the Commerce Clause.
Issues
| Issue | Plaintiff's Argument (Gov’t) | Defendant's Argument (Chambers) | Held |
|---|---|---|---|
| Sufficiency of the evidence | Circumstantial and witness ID evidence (phone records, plate match, hammer, flight, false ID) suffice for a rational juror to convict | Recantation by Torruella and struck IDs undermine any rational conviction | Affirmed: viewing evidence in the light most favorable to jury, a reasonable juror could find guilt beyond a reasonable doubt |
| Admission of eyewitness IDs | IDs were admissible; any suggestiveness was for the jury to weigh or cured by reliability analysis | Pretrial procedures were suggestive; court should have held a reliability hearing and suppressed IDs | No abuse of discretion; Torres’s IDs were stricken (harmless); Torruella’s IDs admissible without pretrial hearing and jury could assess credibility |
| Brady nondisclosure | Disclosures (including detective notes and thumbnail photo) were provided under §3500; in any event the court’s striking of Torres’s IDs cured any prejudice | Failure to disclose pretrial photo use and Google-search notes prejudiced defense | Rejected: no suppression causing prejudice; any nondisclosure was mitigated by court’s actions and timing of disclosures |
| Cell-site location (SCA §2703(d)) | §2703(d) application contained specific and articulable facts linking Twizie phone to robbery/kidnapping investigation | Application failed to meet the §2703(d) standard and SCA authorizes less-than-probable-cause intrusion violating the Fourth Amendment | Affirmed: application met the §2703(d) standard (and facts even supported probable cause); Fourth Amendment challenge rejected on the merits |
| Constitutionality of §1201 (Commerce Clause) | §1201 criminalizes use of instrumentalities of interstate commerce in kidnapping; statute includes element (use of interstate instrumentality) | Statute exceeds Commerce Clause power (facial and as-applied) because it lacks a jurisdictional nexus or the cellphone use was too attenuated | Facial challenge fails: statute targets instrumentalities of interstate commerce (Lopez category 2). As-applied challenge fails: cellphone use was instrumental and not merely incidental to the crimes |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (evidence sufficiency standard for criminal convictions)
- Manson v. Brathwaite, 432 U.S. 98 (admission of eyewitness ID subject to reliability analysis)
- Perry v. New Hampshire, 565 U.S. 228 (due process bars only identifications from unduly suggestive procedures creating substantial likelihood of misidentification)
- Brady v. Maryland, 373 U.S. 83 (prosecution duty to disclose favorable evidence)
- Neil v. Biggers, 409 U.S. 188 (five-factor reliability test for eyewitness ID)
- Illinois v. Gates, 462 U.S. 213 (probable cause as a flexible, common-sense standard)
- United States v. Lopez, 514 U.S. 549 (limits on Congress’s Commerce Clause power categories)
- United States v. Salerno, 481 U.S. 739 (standard for successful facial constitutional challenges)