United States v. Gates, 2013 U.S. App. LEXIS 4255

Gates was indicted in the District of Maine for conspiracy to distribute cocaine base and possession with intent to distribute; a superseding indictment extended the conspiracy period.
Gates proceeded through multiple court-appointed attorneys and litigation on suppression and speedy-trial motions before trial.
On the second trial day Gates pled guilty conditionally to preserve his rights to challenge earlier denials of suppression and dismissal motions. He later sought to withdraw the plea and obtain new counsel.
The district court issued a presentence investigation report; Gates received a 240-month sentence after the plea and subsequent proceedings.
Gates challenged two suppression rulings (motor-vehicle stop and residential search) and raised Speedy Trial Act (STA) concerns, plea-withdrawal issues, and sentencing challenges.
The First Circuit affirmed, concluding there was no reversible error and the sentence was reasonable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motor-vehicle stop legality under Terry framework	Gates contends the stop was without reasonable suspicion.	Gates maintains the speeding stop was pretextual and unsupported.	Stop valid; reasonable suspicion supported initial detention.
Residential search legality under bail-condition and consent	Evidence seized should be suppressed due to improper search.	Consent or bail-condition authority legitimizes the search.	Search justified by consent and/or valid bail condition; suppression not warranted.
Excludability of time under the Speedy Trial Act	District court erred by excluding periods of delay under ends-of-justice findings.	Defense counsel can seek continuances without client consent; exclusions proper.	District court did not abuse discretion; counsel's waivers permitted under STA; some periods waived and others not challenged on appeal remain waived.
Plea withdrawal standard	Withdrawal was warranted by lack of voluntariness and innocence claims.	Plea withdrawal should be granted due to new evidence of innocence and desire for counsel.	No fair and just reason to withdraw; district court acted within its discretion.
Reasonableness of the sentence based on the Sentencing Guidelines	Guidelines-based calculation was reliable and correctly applied.	Due process concerns arise from reliance on untrustworthy materials (Nadeau proffer).	GSR properly calculated; sentence within reasonable range given totality of circumstances.

Whren v. United States, 517 U.S. 806 (1996) (objective reasonableness governs Terry stops)
Ruidíaz v. United States, 529 F.3d 25 (1st Cir. 2008) (reasonableness of initial stop under totality of circumstances)
United States v. Henderson, 463 F.3d 27 (1st Cir. 2006) (scope of actions during a stop may expand with mounting suspicion)
Arvizu v. United States, 534 U.S. 266 (2002) (totality of circumstances test for reasonable suspicion)
Hill v. Hill, 528 U.S. 110 (2000) (attorney authorization can waive speedy-trial rights without defendant consent)
Taylor v. Illinois, 484 U.S. 400 (1988) (implications of counsel's control over trial management matters)
Samson v. California, 547 U.S. 843 (2006) (suspicionless searches of parolees valid under conditioning of submission)
Zapata v. United States, 589 F.3d 475 (1st Cir. 2009) (sentencing evidence may be non-traditional and still reliable for GSR)
Cintrón-Echautegui v. United States, 604 F.3d 1 (1st Cir. 2010) (sentencing evidence assessment and reliability of proffers in GSR)
Gonzalez-Vazquez v. United States, 34 F.3d 19 (1st Cir. 1994) (voluntariness and knowledge in guilty-plea procedures)
Booker v. United States, 543 U.S. 220 (2005) (guidelines are advisory)
Jiménez-Beltre v. United States, 440 F.3d 514 (1st Cir. 2006) (reasonableness review of sentence under 18 U.S.C. § 3553(a))