United States v. Jesse Skyberg, 16-51458

Skyberg pleaded guilty to: possession with intent to distribute ≥50g methamphetamine (21 U.S.C. §841), felon in possession of a firearm (18 U.S.C. §922(g)), and using/possessing a firearm in furtherance of drug trafficking (18 U.S.C. §924(c)).
Officers in full uniform in marked patrol cars approached a running vehicle at night; Skyberg was slumped over the wheel with lights off.
Upon noticing officers, Skyberg placed the vehicle in drive and it lurched forward several times despite passenger officer’s orders to stop and put the car in park.
Officers identified themselves; Skyberg was arrested for evading arrest or detention and the vehicle was searched (inventory search), producing evidence used at trial.
Skyberg moved to suppress evidence seized after the warrantless vehicle search, arguing lack of reasonable suspicion and probable cause for arrest; the district court denied suppression and imposed sentences totaling 180 months.
On appeal Skyberg also requested correction of a clerical sentencing error in the written judgment to reflect the district court’s oral sentence on Count Two (115 months).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to detain Skyberg	Skyberg argues officers lacked reasonable suspicion to approach/detain him	Government: time, vehicle running with lights off, slumped driver, and his reaction provided reasonable suspicion	Court held officers had reasonable, articulable suspicion to detain Skyberg
Whether officers had probable cause to arrest for evading arrest/detention	Skyberg contends facts did not support probable cause for evading	Government: officer testimony, uniforms, identification, Skyberg’s vehicle movements after officer contact supported probable cause	Court held totality of circumstances supported probable cause for arrest
Whether denial of suppression was erroneous	Skyberg argues suppression should have been granted because initial stop/arrest were unconstitutional	Government: suppression denial proper because stop/arrest were lawful and subsequent inventory search was not challenged	Court affirmed denial of suppression
Whether written judgment should be corrected for clerical error	Skyberg requests remand to correct sentencing discrepancy between oral and written judgments	Government acknowledges oral pronouncement controls over written judgment	Court modified judgment to reflect 115 months on Count Two as orally pronounced

Ornelas v. United States, 517 U.S. 690 (establishes de novo review of legal conclusions on suppression and clear-error review of factual findings)
United States v. Gibbs, 421 F.3d 352 (in suppression review, view evidence in light most favorable to prevailing party)
United States v. Gonzalez, 190 F.3d 668 (district court rulings upheld if any reasonable view of evidence supports them)
Illinois v. Wardlow, 528 U.S. 119 (describes reasonable-suspicion analysis for police encounters)
United States v. Watson, 953 F.2d 895 (standard for brief investigative detentions in this circuit)
United States v. Castro, 166 F.3d 728 (discusses probable cause for evading-arrest offenses)
United States v. Green, 964 F.2d 365 (addresses inventory searches and suppression challenges)
United States v. Torres-Aguilar, 352 F.3d 934 (oral pronouncement controls over conflicting written judgment)