United States v. Gloria Taylor
692 F. App'x 114
| 4th Cir. | 2017Background
- Gloria Patricia Taylor was arrested after officers executed a search warrant at her home and vehicles and recovered 286 pounds (about 130 kg) of marijuana from a U-Haul; she was convicted of two counts of using a communications device to facilitate narcotics trafficking and possession with intent to distribute 100+ kg of marijuana, and sentenced to 144 months.
- After the seizure, an officer told Taylor she and her son could be arrested; Taylor then wrote a statement taking responsibility for the seized drugs; she was arrested, her son was not.
- Taylor moved to suppress her written statement, arguing it was coerced because she was threatened with her son’s arrest; the district court denied suppression after an evidentiary hearing.
- During jury deliberations a summary chart (not admitted into evidence) was inadvertently shown to jurors; the district court instructed jurors to disregard and erase any notes and reminded them the chart was not evidence.
- At sentencing the court calculated drug weight well above the jury’s finding by including pre-conspiracy shipments as relevant conduct and applied a 2-level obstruction enhancement for false testimony; Taylor challenged both the quantity calculation and the enhancement and also contested the forfeiture calculation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Suppression: Was Taylor’s written statement coerced? | Officer’s threat to arrest her son coerced her into falsely confessing. | Officer truthfully advised probable cause existed to arrest the son; statement was voluntary under totality of circumstances. | Denial of suppression affirmed; truthful statement about possible arrest was not unduly coercive. |
| Jury impartiality: Did inadvertent display of an unadmitted chart prejudice the jury? | Presentation of the chart during deliberations violated the right to an impartial jury. | Chart had been shown in open court; no identifiable prejudice; court remedied by instruction to disregard. | No reversible error; district court’s curative instruction was appropriate. |
| Sentencing drug-quantity: May court find drug weight beyond jury’s verdict for Guidelines? | Court’s weight finding (≈4945 kg) exceeded jury finding and violated Apprendi/Alleyne. | District court may find relevant conduct and drug weight for sentencing so long as it does not increase statutory maximum. | No Apprendi/Alleyne violation; court permissibly found relevant conduct and approximated weight. |
| Obstruction enhancement: Was 2-level enhancement for false testimony appropriate? | Taylor’s suppression-hearing testimony was truthful. | District court discredited Taylor and found willful falsehoods about coercion. | Enhancement affirmed; appellate court defers to district court credibility findings. |
Key Cases Cited
- United States v. Holmes, 670 F.3d 586 (4th Cir.) (voluntariness standard and totality of circumstances)
- United States v. Umana, 750 F.3d 320 (4th Cir.) (factors for voluntariness inquiry)
- United States v. Braxton, 112 F.3d 777 (4th Cir.) (truthful statements by officers not coercive)
- United States v. Allen, 631 F.3d 164 (4th Cir.) (probable cause and voluntariness context)
- United States v. Lentz, 383 F.3d 191 (4th Cir.) (prejudice presumed when improper evidence reaches jury)
- United States v. Young, 609 F.3d 348 (4th Cir.) (district court’s authority to find sentencing facts beyond jury’s verdict)
- United States v. Agyekum, 846 F.3d 744 (4th Cir.) (relevant conduct at sentencing)
- United States v. White, 810 F.3d 212 (4th Cir.) (elements for obstruction enhancement)
