United States v. Janson Strayhorn
743 F.3d 917
| 4th Cir. | 2014Background
- Two men robbed P&S Coins in August 2010 in North Carolina; Colt Peacemaker was stolen and later found in the defendants’ circle of control.
- Jimmy Strayhorn, while detained for other crimes, directed his brother Janson Strayhorn to rob All American Coins in October 2010 to raise bond money.
- Jimmy’s girlfriend Woodcock owned the Cadillac used in the plots; police tracked calls indicating the plan to use Woodcock’s car.
- Butner police stopped a Cadillac containing Janson Strayhorn, Kenneth Jones, and a Colt Peacemaker later linked to P&S Coins; firearms and zip ties were found in the vehicle and Woodcock’s home.
- Sufficiency challenges were raised to Counts relating to P&S Coins (robbery and firearms) and to Counts relating to All American Coins (conspiracy and firearm).
- The district court denied acquittals on all counts; the appellate court reversed on some P&S Counts and remanded for Alleyne-based resentencing, while affirming others.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for P&S Coins robbery and weapon counts | Strayhorn evidence, including fingerprint on movable duct tape and gun possession, supports guilt | Fingerprint on movables is insufficient without timing or corroborating evidence | Counts One and Two reversed for Janson Strayhorn |
| Sufficiency of evidence for All American Coins conspiracy and firearm counts | Phone transcripts and conduct show agreement to commit the robbery and use of a firearm | Evidence insufficient if not tying actions to the crime; timing issues | Counts Three and Four affirmed for Janson Strayhorn |
| Alleyne error requiring resentencing for Jimmy Strayhorn | Brandishing finding increased the sentence under mandatory minimum | Brandishing not properly submitted as an element | Jimmy Strayhorn remanded for resentencing without the enhanced minimum |
Key Cases Cited
- United States v. Corso, 439 F.2d 956 (4th Cir. 1971) (fingerprints on movables require corroborating timing evidence to sustain conviction)
- United States v. Van Fossen, 460 F.2d 38 (4th Cir. 1972) (fingerprints on movables insufficient without timing)
- United States v. Harris, 530 F.2d 576 (4th Cir. 1976) (note on holdup with additional corroborating evidence suffices)
- United States v. Anderson, 611 F.2d 504 (4th Cir. 1979) (fingerprints on movables supported by other incriminating evidence)
- United States v. Burgos, 94 F.3d 849 (4th Cir. 1996) (fingerprint on plastic bag part of evidence; multiple incriminating facts required)
- United States v. Newsome, 322 F.3d 328 (4th Cir. 2003) (timing and context of possession of stolen property matter for inference of theft)
- Buffey v. United States, 899 F.2d 1402 (4th Cir. 1990) (elements of Hobbs Act conspiracy require coercion affecting interstate commerce)
- United States v. Madrigal–Valadez, 561 F.3d 370 (4th Cir. 2009) (holistic sufficiency review; consider complete evidentiary picture)
- United States v. Williams, 342 F.3d 350 (4th Cir. 2003) (Hobbs Act robbery requires underlying crime plus interstate commerce impact)
- United States v. Mitchell, 104 F.3d 649 (4th Cir. 1997) (elements of 18 U.S.C. 924(c)(1)—used or carried during and relating to violent crime)