United States v. Palmer Robinson
670 F. App'x 144
| 4th Cir. | 2016Background
- Palmer Robinson was tried in a bench trial before a magistrate judge and convicted of DUI, driving with BAC ≥ .08, unsafe operation/failure to maintain control, and vandalism of government property under federal regulations.
- The district court affirmed the magistrate judge’s convictions; Robinson appealed to the Fourth Circuit.
- On appeal Robinson raised two principal challenges: (1) the magistrate judge erred by taking judicial notice that the U.S. Park Police are authorized to perform law enforcement functions on U.S. Fish and Wildlife Service land, and (2) the Government’s trial evidence was insufficient to support the convictions.
- The magistrate judge had relied on an officer’s testimony in taking judicial notice under Federal Rule of Evidence 201.
- The appellate court reviewed evidentiary rulings for abuse of discretion and sufficiency of the evidence de novo (but defers to factfinder credibility determinations).
Issues
| Issue | Plaintiff's Argument (Robinson) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Judicial notice of Park Police authority on USFWS land | Magistrate erred in taking judicial notice of Park Police authority there | Magistrate permissibly relied on officer testimony to take judicial notice under Fed. R. Evid. 201 | Affirmed — no abuse of discretion in taking judicial notice |
| Sufficiency of evidence for convictions | Evidence was insufficient to support findings of guilt; challenges credibility | Trial testimony and evidence provided substantial support for convictions; credibility determinations are for the factfinder | Affirmed — sufficient evidence when viewed in government’s favor |
Key Cases Cited
- United States v. Bursey, 416 F.3d 301 (4th Cir. 2005) (standard of review for district court affirmance of magistrate)
- United States v. Faulls, 821 F.3d 502 (4th Cir. 2016) (abuse of discretion review for evidentiary rulings)
- United States v. Bran, 776 F.3d 276 (4th Cir. 2015) (standard for reviewing sufficiency of the evidence)
- United States v. Louthian, 756 F.3d 295 (4th Cir. 2014) (deference to factfinder on credibility determinations)