United States v. Leconie Williams, IV
2014 U.S. App. LEXIS 1251
| 4th Cir. | 2014Background
- Around 1:00 a.m., Officer McCann observed Williams’s vehicle stopped in the middle of a residential roadway for ~30–60 seconds; Williams waved McCann to pass and then pulled over after lights were activated.
- Sergeant Finn saw Williams remove an object from his waistband and drop it into the car; officers recovered a gun on the driver’s floorboard and Williams later admitted ownership.
- Williams was cited under Md. Code Ann., Transp. § 21-1001(b) (prohibiting leaving a vehicle standing so as to obstruct traffic outside residential/business districts).
- The government indicted Williams on 18 U.S.C. § 922(g)(1) (felon in possession) and § 922(k) (altered serial number); motion to suppress the gun was denied because the stop was supported by suspicion of a different Maryland traffic offense (§ 21-1004(a)).
- District court excluded evidence of prior civil allegations of officer misconduct under Fed. R. Evid. 404(b)/403; Williams was ultimately convicted of being a felon in possession and sentenced to 120 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of the stop under the Fourth Amendment | Govt: Stop lawful because officer observed a traffic violation (vehicle stopped in travel lane) giving reasonable suspicion/probable cause | Williams: Stop unlawful because citation cited §21-1001(b), which doesn’t apply in residential districts, so the stop lacked legal basis | Affrmed — stop lawful: officer had reasonable suspicion under the applicable Maryland provision (§21-1004(a)) for stopping a vehicle in the middle of the road |
| Officer’s citation error (wrong code section) as invalidating stop | Govt: Officer’s mis-cited statute does not negate reasonable belief that some traffic law was violated | Williams: Incorrect statutory citation shows no lawful basis for stop | Affirmed — an officer need not cite the exact statute; conduct observed was prohibited by a closely related provision |
| Sufficiency of evidence that vehicle was >12 inches from curb | Govt: Officer testimony that vehicle was in middle of road plus conduct (waving officer to pass) supports violation | Williams: Record insufficient to prove vehicle stopped more than 12 inches from curb | Affirmed — district court credited officer testimony; ample room existed to stop at curb per record |
| Exclusion of prior police-misconduct evidence under Rule 404(b)/403 | Williams: Prior civil suits showing alleged officer misconduct were probative to credibility/intent and should be admitted | Govt: Prior claims were stale, marginally relevant, potentially confusing, time-consuming, and some materials implicate other rules (e.g., Rule 408) | Affirmed — district court did not abuse discretion in excluding the dated, minimally probative evidence |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (1996) (traffic violation observation justifies a vehicle stop even if officer has other motivations)
- United States v. Wilson, 205 F.3d 720 (4th Cir. 2000) (automobile stop is a seizure requiring probable cause or reasonable suspicion)
- United States v. Hassan El, 5 F.3d 726 (4th Cir. 1993) (observing a traffic offense provides probable cause to stop)
- United States v. Hughes, 606 F.3d 311 (6th Cir. 2010) (officer need not cite exact statute at time of stop; reasonable belief that law was violated suffices)
- United States v. McDonald, 453 F.3d 958 (7th Cir. 2006) (an officer’s mistake of law cannot support probable cause when the conduct is not illegal)
- United States v. Queen, 132 F.3d 991 (4th Cir. 1997) (four-factor test for admissibility under Rule 404(b))