United States v. Dante Sheffield
832 F.3d 296
| D.C. Cir. | 2016Background
- On June 8, 2011, D.C. police recognized Dante Sheffield near a prior PCP investigation, observed the driver (Brande Dudley) make two turns without signaling, and stopped the car.
- Officers smelled marijuana, saw numerous air fresheners, ordered occupants out, and searched the vehicle; an armrest console contained a lemon-juice bottle with liquid that officers and a DEA chemist later identified as PCP.
- Sheffield was arrested as a passenger; he made spontaneous statements at arrest ("everything is mine" and that "they don’t have a strong case") before receiving Miranda warnings.
- At trial the government introduced chain-of-custody and testing testimony; only about one ounce was submitted to the DEA (per DEA rules) and tested; the remaining liquid was admitted but not tested by DEA.
- Jury convicted Sheffield of possession with intent to distribute 100+ grams of PCP; district court applied a career-offender Sentencing Guidelines enhancement and sentenced him to 230 months.
- On appeal Sheffield challenged suppression of the evidence and statements, admission of a 2002 PCP conviction under Rule 404(b), denial of post-trial testing, and the career-offender enhancement; the court affirmed the conviction but vacated the sentence and remanded for resentencing without the career-offender enhancement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of traffic stop | Stop was pretext targeting Sheffield; lack of citation shows motive | Officers had probable cause: driver twice failed to signal | Stop was objectively reasonable under Whren; probable cause for stop upheld |
| Lawfulness of vehicle search | Search exceeded authority; Sheffield (passenger) lacked standing | Smell of marijuana + many air fresheners gave probable cause to search compartments | Probable cause to search vehicle and armrest console affirmed (automobile exception) |
| Admission of pre-arrest statements (Miranda) | Statements were custodial and unmirandized; should be suppressed | Statements were spontaneous and not elicited by interrogation | Miranda did not apply; statements admissible because not the product of interrogation |
| Admission of 2002 PCP conviction under Fed. R. Evid. 404(b) | Prior conviction unduly stale and prejudicial | Government: prior dealing probative of knowledge/intent | Admission was erroneous under Rule 403/404(b) but error was harmless given limited presentation and overwhelming other evidence |
| Motion for post-trial independent testing of untested PCP | Testing remaining liquid could exculpate or undermine quantity/identity proof | Extensive chain-of-custody, field tests, DEA test of one-ounce sample, and trial inspection made new testing unlikely to produce acquittal | Denial of motion for testing (treated as Rule 33 new-trial motion) was not an abuse of discretion |
| Sentencing: career-offender enhancement | Enhancement improper because attempted robbery does not qualify as "crime of violence" | Government relied on prior attempted robbery and PCP convictions to trigger Guidelines career-offender status | Enhancement vacated: residual clause invalid under Johnson; attempted robbery does not categorically qualify under elements clause; remand for resentencing without enhancement |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic stop objective-reasonableness test)
- Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation)
- Rhode Island v. Innis, 446 U.S. 291 (definition of interrogation and its functional equivalent)
- United States v. Ross, 456 U.S. 798 (scope of vehicle search when probable cause exists)
- United States v. Turner, 119 F.3d 18 (D.C. Cir. 1997) (smell of marijuana and other indicia support vehicle search)
- United States v. Crowder, 141 F.3d 1202 (D.C. Cir. 1998) (prior drug-dealing evidence probative of knowledge/intent)
- Old Chief v. United States, 519 U.S. 172 (limitations on admissibility of prior convictions under Rule 403)
- Johnson v. United States, 576 U.S. 591 (2015) (invalidating ACCA residual clause for vagueness; applied to Guidelines residual clause)
- Descamps v. United States, 570 U.S. 254 (2013) (modified categorical approach and divisible vs. indivisible statutes)
- Begay v. United States, 553 U.S. 137 (2008) (categorical approach to crimes of violence)