United States v. Chase Logan Guzman, 926 F.3d 991

Background

ATF investigation (CI and recorded calls) established Morales trafficked methamphetamine from Wichita to Sioux Falls; a controlled buy occurred in April 2016.
On Sept. 22, 2016, surveillance identified Morales and Guzman at a Days Inn and at Jerri Young Running Crane’s house; agents followed their Kansas-plated minivan.
State trooper Steen (told by detectives that occupants had drugs/firearms) performed a ruse traffic stop and, during the stop, officers found ~1 lb marijuana in the van; Guzman had a loaded Glock 19 and ~29 g methamphetamine on his person.
A warrant search of Young Running Crane’s home yielded ~2 lbs methamphetamine and ~2 lbs marijuana; a truck owned by Guzman had ammunition.
Morales and Guzman were indicted for conspiracy to distribute 500+ g methamphetamine; Guzman also charged under 18 U.S.C. § 924(c) for using/carrying a firearm in relation to a drug trafficking crime.
District court denied suppression motions; Guzman pleaded guilty (preserving certain issues) and was sentenced; Morales went to trial, convicted, and both appealed (suppression, evidentiary, and sentencing issues).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of ruse traffic stop / suppression	Gov’t: surveillance positively identified Morales & Guzman in van before stop; officers had reasonable suspicion from CI, controlled buy, recordings, and observations	Morales/Guzman: not specifically identified in van before stop; therefore Steen lacked reasonable suspicion	Court: Affirmed — district court’s factual finding of positive ID not clearly erroneous; team knowledge and corroborated CI supplied reasonable suspicion.
Applicability of Dean v. United States to permit variance below statutory minimum	Gov’t: Dean does not allow district courts to impose a sentence below a statutory mandatory minimum	Guzman: Dean’s rationale should permit variance below the drug-count statutory minimum because of mandatory consecutive § 924(c) term	Court: Affirmed — Dean only allows consideration of § 924(c) when varying from Guidelines, not authority to go below statutory minimum; Guzman’s challenge fails on merits.
Admission of evidence of marijuana and firearms as intrinsic (Rule 404(b)/403)	Gov’t: evidence of marijuana and guns was intrinsic/contextual to the meth conspiracy and probative; any prejudice outweighed	Morales: such evidence was improper bad-act evidence under Rule 404(b) and unduly prejudicial under Rule 403	Court: Affirmed — evidence was inextricably intertwined or completed the story, admissible as intrinsic; Rule 403 balance favored admission.
Sentencing enhancements and drug-quantity attribution for Morales	Gov’t: include offered-but-not-seized 566.9 g meth (converted to marijuana-equivalent) and apply weapon, threats, and leader-role enhancements based on the record	Morales: 566.9 g was not seized or proven accessible; challenges to weapon, threat, and organizer enhancements	Court: Affirmed — district court’s drug-quantity approximation supported by testimony; weapon enhancement justified by Guzman’s possession and related conduct; threats via messages tied to drug activity; leader-role enhancement supported by participant-count and ongoing supplier relationship.

Key Cases Cited

United States v. Walker, 840 F.3d 477 (8th Cir.) (standard of review for suppression: de novo review of legal question; factual findings for clear error)
United States v. Hurd, 785 F.3d 311 (8th Cir.) (suppression-review principles)
United States v. Frencher, 503 F.3d 701 (8th Cir.) (district-court credibility findings on suppression hearings are virtually unassailable on appeal)
United States v. Thomas, 760 F.3d 879 (8th Cir.) (Rule 404(b) vs. intrinsic-evidence distinction)
United States v. O’Dell, 204 F.3d 829 (8th Cir.) (Rule 403 balancing and admission of contextual drug evidence)
United States v. Sykes, 854 F.3d 457 (8th Cir.) (supplier/ongoing-source relationships can support role-in-organizing enhancement)