United States v. Mario Baker
2013 U.S. App. LEXIS 11921
| 4th Cir. | 2013Background
- Baker was convicted of federal firearms and drug offenses based on a search of his vehicle during a traffic stop.
- During the stop, Brown, the front-seat passenger, was frisked; a gun was found, and Brown was arrested, with drugs, cash, and a digital scale found on him.
- Officer Nelson then searched Baker’s vehicle and found heroin, crack cocaine, methadone, cash, and a handgun in the glove box.
- Baker was indicted on multiple counts; his counsel moved to sever one prior-count but did not file a suppression motion.
- On appeal, the Supreme Court decided Arizona v. Gant after Baker’s briefing; Baker argued ineffective assistance for not challenging the search under Gant.
- The district court denied relief; the Fourth Circuit later held the search was justified by the automobile exception and Baker lacked standing to challenge Brown’s search, affirming.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for not raising Gant on appeal | Baker | Baker | No ineffective assistance; search upheld under automobile exception |
| Whether the vehicle search was justified by the automobile exception independent of Gant | Baker | Baker | Search justified by probable cause under automobile exception |
| Whether Baker had standing to challenge the Brown search | Baker | Baker | Baker lacked standing to challenge Brown’s frisk/search |
| Whether Davis good-faith exception bars suppression for pre-Gant searches | Baker | Baker | Good-faith exception applies; suppression not warranted |
Key Cases Cited
- Arizona v. Gant, 556 U.S. 332 (2009) (limits vehicle searches incident to arrest to two specified circumstances)
- Chimel v. California, 395 U.S. 752 (1969) (scope of permissible searches incident to arrest)
- New York v. Belton, 453 U.S. 454 (1981) (early vehicle-search framework prior to Gant)
- Thornton v. United States, 541 U.S. 615 (2004) (vehicle searches post-arrest)
- Davis v. United States, 131 S. Ct. 2419 (2011) (good-faith exception extends to searches conducted under binding precedent)
- Kellam, 568 F.3d 125 (2009) (car search sustained under automobile exception post-Gant)
- United States v. Wilks, 647 F.3d 520 (2011) ( Fourth Circuit on pre-Gant searches)
- United States v. Milton, 52 F.3d 78 (1995) ( Belton framework prior to Gant)
- United States v. Ortiz, 669 F.3d 439 (2012) (probable cause standard for automobile searches)
- Rakas v. Illinois, 439 U.S. 128 (1979) (standing to challenge a search)
- United States v. Leon, 468 U.S. 897 (1984) (good-faith exception rationale)