United States v. Paris Young
6 F.4th 804
| 8th Cir. | 2021Background
- Paris Young (Black) fled a traffic stop; officers found 12.4g crack cocaine in 46 bags, a small amount of marijuana, and a loaded gun with scratched-off serial number.
- Indicted on four counts: possession with intent to distribute cocaine base, possession of a firearm in furtherance of drug trafficking, felon in possession, and possession of a firearm with an obliterated serial number.
- During voir dire Young submitted questions on race and implicit bias; the district court used party-submitted questions, asked broadly about biases and specifically whether race/gender would affect jurors’ decisions, and no juror raised a hand.
- Jury convicted on all counts; PSR applied the ACCA based on prior Missouri convictions (second-degree murder and two sales of cocaine base), triggering a statutory minimum and increasing Young’s sentence to a multi-decade term.
- Young appealed, arguing (1) the district court abused discretion by not probing implicit racial bias in voir dire, and (2) the ACCA enhancement was improper because Missouri’s statute allegedly criminalized substances not on the federal schedule.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court erred by not asking voir dire questions designed to reveal implicit racial bias | Young: court should have questioned jurors specifically to elicit implicit bias; failure was reversible error | Government: no constitutional rule requiring implicit-bias questioning; court asked about race and eliminated reasonable possibility of prejudice | No abuse of discretion; not constitutionally required; court asked about race and reasonably avoided bias; declined to impose a rule requiring implicit-bias questions |
| Whether two prior Missouri drug convictions qualify as ACCA "serious drug offenses" | Young: Missouri statute was broader than federal controlled-substance definition, so convictions do not necessarily match federal "serious drug offense" | Government: Missouri statute is divisible by drug identity; records show Young’s convictions involved cocaine base, a federally listed controlled substance | Affirmed; under the modified categorical approach the prior sales were of cocaine base, which qualifies as a federal controlled substance and thus as ACCA predicates |
Key Cases Cited
- Rosales-Lopez v. United States, 451 U.S. 182 (explains when voir dire on racial prejudice is constitutionally required)
- Borders v. United States, 270 F.3d 1180 (sets standard for when failure to inquire about racial prejudice is an abuse of discretion)
- Pendleton v. United States, 832 F.3d 934 (deference to district court’s voir dire judgments; abuse-of-discretion review)
- Llach v. United States, 739 F.2d 1322 (distinguishes need for racial-bias inquiry in nonviolent, victimless cases and emphasizes trial-court responsibility)
- Ham v. South Carolina, 409 U.S. 524 (requires inquiry where racial issues are intertwined with trial, e.g., alleged framing by law enforcement)
- United States v. Nelson, 347 F.3d 701 (discusses voir dire adequacy and protection against prejudice)
- United States v. Jones, 934 F.3d 842 (applies divisible-statute/modified categorical approach to Missouri drug convictions)
- In re Murchison, 349 U.S. 133 (articulates the fundamental requirement of absence of actual bias in fair tribunals)
- Peña-Rodriguez v. Colorado, 137 S. Ct. 855 (underscores the importance of combating bias to preserve equal treatment under law)