United States v. Michael Talton Williams
2013 U.S. App. LEXIS 20133
| 11th Cir. | 2013Background
- On March 24, 2011, Miami police knocked on a rooming-house door to investigate narcotics complaints; Michael Taitón Williams answered and was asked for consent to be searched.
- Officers Delgado and Moreno testified Williams consented; Williams testified he did not and pushed the officer when the officer reached into his pockets.
- Williams fled into the building, was chased, struggled with officers, and during the struggle a loaded 9mm Glock fell from his waistband; officers then arrested and searched him incident to arrest, recovering crack/powder cocaine, marijuana, and cash from his pockets.
- Williams filed a pretrial motion to suppress evidence and statements as the product of an unlawful, nonconsensual search; the district court denied suppression after an evidentiary hearing that credited the officers’ testimony.
- A jury convicted Williams of: (1) possession of a firearm by a felon (18 U.S.C. § 922(g)); (2) possession with intent to distribute crack cocaine (21 U.S.C. § 841(a)(1)); and (3) possession of a firearm in furtherance of a drug trafficking crime (18 U.S.C. § 924(c)). He was sentenced to a total of 334 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of gun/drugs/statements — suppression | Government: officers lawfully conducted a knock-and-talk, obtained consent, and, after Williams assaulted an officer, had probable cause to arrest and search incident to arrest. | Williams: no valid consent; if consent given it was revoked when he pushed the officer; therefore evidence/results and statements should be suppressed. | Denial of suppression affirmed. District court credibility findings (officers credible) not clearly erroneous; search lawful as consensual and, after assault, as incident to lawful arrest. |
| Sufficiency of evidence for § 924(c) (firearm "in furtherance" of drug trafficking) | Government: circumstantial and expert testimony showed dealer-level quantities, colored packaging, proximity of loaded, accessible gun, and typical drug-dealer use of firearms. | Williams: insufficient evidence linking the gun to drug trafficking or to his intent to further trafficking. | Conviction affirmed. Evidence (weapon accessibility, loaded status, proximity to drugs/proceeds, expert testimony) permitted a rational jury to find the gun was possessed in furtherance of drug trafficking. |
| Batson/peremptory strike (denial of one defense peremptory) | Government: challenged multiple defense strikes as racially motivated; court sustained objection as to juror McCarthy and seated him. | Williams: district court erred in sustaining Batson objection and deprived him of a federal-rule peremptory strike; seeks automatic reversal. | Even assuming error, harmless-error review applies (Rivera). Any erroneous denial of a Rule 24 peremptory challenge is not structural; Williams did not show substantial-rights prejudice. Conviction affirmed. |
| Standard of review for credibility/findings on suppression | N/A (government position reflected in court's analysis) | Williams: challenges credibility determination and factual findings. | Appellate court defers to district court’s credibility findings unless clearly erroneous; here those findings were supported and not clearly erroneous. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (establishes Batson framework for race-based challenges to peremptory strikes)
- Rivera v. Illinois, 556 U.S. 148 (erroneous denial of peremptory strike is subject to harmless-error review; no freestanding constitutional right to peremptories)
- United States v. Woodard, 531 F.3d 1352 (11th Cir.) (elements and factors for § 924(c) "in furtherance" inquiry)
- United States v. Timmons, 283 F.3d 1246 (11th Cir.) (presence of a gun in dominion/control not alone sufficient for § 924(c))
- United States v. Taylor, 458 F.3d 1201 (11th Cir.) (knock-and-talk does not implicate the Fourth Amendment)
- United States v. Milian-Rodriguez, 759 F.2d 1558 (11th Cir.) (hot pursuit exception permitting warrantless entry)
- United States v. Goddard, 312 F.3d 1360 (11th Cir.) (search incident to lawful arrest requires no additional justification)