United States v. Jerry Edwards
666 F. App'x 253
| 4th Cir. | 2016Background
- Jerry Lee Edwards was indicted on drug and firearm charges following an arrest at a motel parking lot: possession with intent to distribute cocaine base and cocaine, possession of a firearm in furtherance of drug trafficking, and possession of a firearm by a felon.
- Edwards moved to suppress evidence seized during the stop and arrest; the district court denied the motion.
- Edwards waived a jury trial and stipulated to facts sufficient to convict to preserve his right to appeal the suppression ruling; the court sentenced him to 130 months' imprisonment.
- Officers stopped Edwards in a motel parking lot known for drugs and prostitution in a generally high-crime area; his car was parked across two spaces with no lights on and he remained in the vehicle instead of going into the motel.
- Officers observed Edwards in possession of marijuana after approaching the vehicle, which provided probable cause for arrest.
- Edwards also challenged the addition of a criminal history point for prior North Carolina common-law robbery convictions; the government argued he waived review by withdrawing objections at sentencing.
Issues
| Issue | Plaintiff's Argument (Edwards) | Defendant's Argument (United States) | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to stop Edwards | Stop lacked reasonable suspicion; factors (motel location, parking) insufficient | Totality of circumstances (motel known for drugs/prostitution, high-crime area, parked across spaces, no lights, stayed in car) supported reasonable suspicion | Stop was supported by reasonable suspicion; suppression denial affirmed |
| Whether district court erred in adding a criminal history point for consolidated robbery convictions | Point misapplied because convictions not crimes of violence and consolidation means point shouldn’t apply | Edwards waived appellate review by stating no outstanding objections to revised PSR at sentencing | Claim waived; appellate review barred; sentencing challenge rejected |
Key Cases Cited
- United States v. Davis, 690 F.3d 226 (4th Cir. 2012) (standard of review for suppression factual findings and legal determinations)
- United States v. Foster, 634 F.3d 243 (4th Cir. 2011) (investigative detention requires reasonable, articulable suspicion)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (suspicion must be more than an inchoate hunch)
- United States v. Perkins, 363 F.3d 317 (4th Cir. 2004) (give due weight to officers’ common-sense judgments)
- United States v. Branch, 537 F.3d 328 (4th Cir. 2008) (consider all factors known to officer; traffic/ordinance violations justify detention)
- United States v. Hernandez-Mendez, 626 F.3d 203 (4th Cir. 2010) (reasonable suspicion inquiry is fact-intensive; evaluate combined factors)
- United States v. Foreman, 369 F.3d 776 (4th Cir. 2004) (innocent-travel factors may together give rise to reasonable suspicion)
- Whren v. United States, 517 U.S. 806 (1996) (pretextual basis for stop does not invalidate stop supported by objective grounds)
- United States v. Wilson, 2 F.3d 226 (7th Cir. 1993) (violation of local ordinance can justify investigatory stop)
- United States v. Robinson, 744 F.3d 293 (4th Cir. 2014) (distinguishing waiver from forfeiture; waived issues not reviewable on appeal)