United States v. Major Todd, 431 F. App'x 412

Todd’s plot to steal over $800,000 in ink cartridges was an inside job at Flextronics Memphis; Willie Hardin stole items and sold them to Todd and others, later supplying 400 cartridges for $200 and escalating to pallets of cartridges.
Hardin recruited Larry Brown and Valerie Smith; Brown and Smith later tipped off management, leading to police involvement.
Hampton of the Auto Cargo Task Force, with Flextronics, manipulated the sting by having Brown and Smith play along, while undercover Smith directed pallets onto a truck.
Todd hired Lawrence Mitchell to transport the pallets; a vehicle and trailer were arranged, after which the trailer used in the theft was reported stolen.
The theft occurred on August 18, 2005; police intervened en route, Todd was arrested after being seen near the truck and Taurus, and he confessed after waiving Miranda rights.
Todd was indicted on two counts of interstate transportation of stolen goods under 18 U.S.C. § 2314, convicted at trial, and sentenced to 51 months under the Guidelines including a leadership enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the confession was properly admitted.	Todd contends lack of probable cause tainted confession.	Government argues probable cause existed; Todd was seen walking from the car to the truck.	Probable cause supported; admission proper.
Whether Rule 608(b) barred certain impeachment witnesses.	Todd sought extrinsic impeachment under 608(b).	District court acted within discretion to bar the witnesses.	Court did not abuse discretion; Rule 608(b) applied.
Whether cross-examination about other witnesses’ lies violated fairness.	Cross-examination undermined fairness.	No plain error; question not plainly improper.	No plain error; fair trial.
Whether there was sufficient evidence Todd knew the trailer was stolen.	Evidence shows Todd arranged for trailer and knew it was stolen.	Evidence supports knowledge of theft.	Sufficient evidence; reasonable jury could find knowledge.
Whether the two-level leadership enhancement § 3B1.1(c) applied.	Todd controlled or materially influenced the plot.	Todd acted as key strategist and recruiter; enhancement warranted.	Enhancement proper; district court’s determination supported.

Maryland v. Pringle, 540 U.S. 366 (2003) (probable cause assessment under totality of circumstances)
United States v. Gross, 624 F.3d 309 (6th Cir. 2010) (probable-cause standard for arrest; factual findings reviewed for clear error)
United States v. Seymour, 468 F.3d 378 (6th Cir. 2006) (Rule 608(b) extrinsic impeachment limits)