United States v. Maurice Davis
664 F. App'x 150
| 3rd Cir. | 2016Background
- Maurice Lebron Davis was convicted by a jury of four Hobbs Act robberies and four attempted robberies; sentenced to 235 months’ imprisonment on each count, concurrently. Appeals court affirmed.
- Police arrested Davis after an Arby’s early-morning incident (smashed drive‑through window); physical evidence at arrest included glass in Davis’s shoe and blood‑stained, ripped clothes whose DNA matched Davis.
- Investigators recovered an encrypted prison‑letter instructing an associate to break an Arby’s window, cell phones linked to Davis and an associate (Flounoy), and photos consistent with seized items and timing.
- Cell‑tower records placed a phone number associated with Davis near multiple fast‑food robbery/attempt locations around the crime times; some calls connected Davis’s number to Flounoy’s number.
- Eyewitnesses at several scenes described a lone male wearing a mask/bandana; modus operandi across incidents: early‑morning fast‑food robberies, window‑smashing or threats to employees, similar disguises and geography.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to support convictions | Government: combined physical evidence, cell‑tower data, witness IDs, letters, phones, modus operandi suffice | Davis: evidence is fragmentary and circumstantial; cannot link him to each charged scene | Affirmed — viewing record as a whole, evidence was sufficient for each count |
| Proof of specific intent required for Hobbs Act robbery | Government: intent may be inferred from circumstantial evidence and conduct | Davis: Government failed to prove intent to commit robbery for charged acts | Affirmed — intent may be proven circumstantially and was adequately supported |
| Use of modus operandi evidence | Government: patterns across incidents are probative to link offenses | Davis: pattern evidence is improper or insufficient to tie him to other scenes | Affirmed — modus operandi admissible and properly considered as part of overall proof |
| Reliance on cell‑tower location data and phone records | Government: cell‑tower data is reliable to place a device near crime scenes and show communications | Davis: cell data is imprecise and cannot definitively place him at scenes | Affirmed — cell‑tower evidence admissible and, combined with other proofs, sufficient |
Key Cases Cited
- United States v. Powell, 693 F.3d 398 (3d Cir. 2012) (standard for reviewing sufficiency of the evidence)
- United States v. Jannotti, 673 F.2d 578 (3d Cir. 1982) (intent may be proven circumstantially)
- United States v. Iglesias, 535 F.3d 150 (3d Cir. 2008) (sufficiency principles applied to circumstantial intent evidence)
- United States v. Culbert, 435 U.S. 371 (1978) (purpose of the Hobbs Act)
- United States v. Jones, 918 F. Supp. 2d 1 (D.D.C. 2013) (discussion of cell‑tower data as location evidence)