United States v. Franklin Mills
20-4187
| 4th Cir. | Sep 17, 2021Background
- Defendant Franklin Alexander Mills appealed his conviction for possession of a firearm by a felon and the district court’s revocation of his prior supervised release.
- Charged under 18 U.S.C. § 922(g)(1); district court sentenced Mills to 115 months on the new offense and a consecutive 24-month term for the supervised-release violation.
- Mills moved to dismiss the indictment for failure to allege essential elements; the district court denied the motion.
- Mills moved to suppress a firearm seized from a vehicle, arguing a Fourth Amendment violation; the district court found Mills abandoned the vehicle and denied suppression.
- He also challenged (1) admission of evidence of a prior conviction at trial and (2) the jury instructions on § 922(g); both were rejected by the district court.
- The Fourth Circuit reviewed the challenges and affirmed both the criminal conviction and the supervised-release revocation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of indictment (elements alleged) | Mills: indictment fails to allege every essential element of § 922(g) offense | Govt: indictment alleges essential elements and is legally sufficient | Denied — indictment was sufficient to allege § 922(g) offense |
| Motion to suppress (vehicle search) | Mills: search violated Fourth Amendment; vehicle privacy retained | Govt: Mills voluntarily abandoned the vehicle, forfeiting any expectation of privacy | Denied — court found abandonment; suppression not warranted |
| Admission of prior conviction evidence | Mills: prior-conviction evidence was improper and prejudicial | Govt: evidence admissible; any error was harmless | Denied — no reversible evidentiary error; any error harmless |
| Jury instruction on § 922(g) elements | Mills: instruction misstated law and could mislead jury | Govt: instruction correctly stated legal elements | Denied — instruction proper when read in context of record |
| Revocation of supervised release based on verdict | Mills: court erred in relying on jury verdict to revoke release | Govt: revocation may rely on criminal conviction; court acted within discretion | Denied — revocation proper given no reversible error in conviction |
Key Cases Cited
- United States v. Engle, 676 F.3d 405 (4th Cir.) (standard for reviewing denial of motion to dismiss indictment)
- United States v. Rendelman, 641 F.3d 36 (4th Cir.) (indictment sufficiency test)
- Greer v. United States, 141 S. Ct. 2090 (2021) (interpretation of § 922(g) indictment requirements)
- United States v. Moody, 2 F.4th 180 (4th Cir.) (§ 922(g) element analysis)
- United States v. Smith, 939 F.3d 612 (4th Cir.) (indictment and instruction precedent)
- United States v. Pulley, 987 F.3d 370 (4th Cir.) (standard of review for suppression rulings)
- United States v. Ferebee, 957 F.3d 406 (4th Cir.) (abandonment and expectation of privacy)
- Rakas v. Illinois, 439 U.S. 128 (1978) (legitimate expectation of privacy framework)
- United States v. Faulls, 821 F.3d 502 (4th Cir.) (abuse-of-discretion standard for evidentiary rulings)
- United States v. Cone, 714 F.3d 197 (4th Cir.) (harmless-error analysis for evidentiary mistakes)
- United States v. Miltier, 882 F.3d 81 (4th Cir.) (review of jury instructions)
- United States v. Dennison, 925 F.3d 185 (4th Cir.) (standard for reviewing supervised-release revocations)