United States v. Maurice Williams
413 U.S. App. D.C. 223
| D.C. Cir. | 2014Background
- MPD investigated suspected drug activity at a Ninth Street, N.W. house; undercover observations led officers to watch the house and its visitors.
- On Oct. 21, 2011 Officer Thompkins followed Maurice Williams’ white Chevrolet after seeing him leave the house and believing he was not wearing a seatbelt; officers stopped the car, smelled marijuana, and found marijuana and powder cocaine in the center console.
- Police obtained a warrant and searched the Ninth Street house the same day, recovering crack and powder cocaine and evidence linking Williams to the residence; Williams was later indicted on four drug counts.
- On Feb. 1, 2012 Williams was arrested at the police station by ruse; officers seized his keys, activated his key fob to locate a blue sedan, smelled marijuana at the vehicle, used a drug dog that alerted, and recovered crack cocaine and marijuana from the car.
- Williams moved to suppress evidence from both vehicle stops and from the house; the district court denied suppression, a jury convicted Williams on all counts, and he was sentenced to 63 months. Williams appealed arguing Fourth Amendment violations, improper prosecutorial vouching, and sentencing-variance error under 18 U.S.C. § 3553(a)(6).
Issues
| Issue | Plaintiff's Argument (Williams) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Lawfulness of Oct. 21 traffic stop (seatbelt) | Stop unconstitutional because Williams was actually wearing a seatbelt; no probable cause | Officer reasonably (objectively) believed seatbelt was unbuckled; reasonable mistake supports stop | Stop lawful: officer’s belief was objectively reasonable; evidence not suppressed |
| Search of blue sedan after key-fob activation (Feb. 1) | Activating key fob was an unlawful warrantless search; subsequent vehicle search unlawful | Keys seized incident to arrest; activating fob not argued below (waived); dog alert and smell supplied probable cause; automobile exception applies | Key-fob claim waived; vehicle search lawful under probable cause and automobile exception |
| Prosecutor’s closing (vouching for police) | Prosecutor vouched for officers’ credibility improperly in rebuttal | Rebuttal addressed defense attacks on officers; statements were minor | One comment constituted plain error in theory but was harmless: instructions mitigated prejudice; no reversal |
| Sentencing variance under §3553(a)(6) (D.C. vs. federal guideline disparity) | Requested downward variance because D.C. Guidelines produce lower sentences | §3553(a)(6) addresses disparities among federal defendants, not federal vs. D.C.; district court properly considered but denied variance | No legal error: circuit precedent holds §3553(a)(6) does not authorize variance for federal vs. D.C. guideline disparities |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (officer’s subjective motivations do not invalidate traffic stop where probable cause exists)
- Hill v. United States, 131 F.3d 1056 (D.C. Cir. 1997) (officer’s reasonable belief about a traffic violation can justify a stop; determine objective reasonableness)
- Robinson v. United States, 414 U.S. 218 (search incident to lawful arrest justifies seizure of items on person)
- Hill v. California, 401 U.S. 797 (police may make reasonable mistakes of fact in arrest situations)
- Florida v. Harris, 133 S. Ct. 1050 (drug-dog alert can establish probable cause absent evidence of unreliability)
- Pennsylvania v. Labron, 518 U.S. 938 (automobile exception: probable cause + vehicle mobility permits warrantless search)
- United States v. Washington, 670 F.3d 1321 (D.C. Cir. 2012) (§3553(a)(6) concerns disparities among federal defendants; federal vs. D.C. guideline differences not a basis for variance)
- United States v. Boyd, 54 F.3d 868 (D.C. Cir. 1995) (prosecutorial vouching for police credibility is improper)