United States v. Rolando Huntley
530 F. App'x 454
6th Cir.2013Background
- Huntley was charged with being a felon in possession of a firearm and obstruction of justice after an encounter with Detroit police stemming from an assault at a gas station.
- Officers recovered a gun Huntley allegedly left near a pay phone and Huntley was ultimately identified after fingerprint processing.
- Huntley moved to suppress evidence from a Terry stop, which the district court denied after an evidentiary hearing.
- Huntley pled guilty to the felon-in-possession count; the obstruction count was dismissed on the government's motion, and the PSR suggested a §3C1.1 enhancement for obstruction.
- At sentencing, the district court overruled Huntley’s objection and imposed a two-level obstruction of justice enhancement, resulting in a 108-month sentence.
- Huntley appealed, but did not preserve appellate rights to challenge the suppression ruling, and the court affirmed the conviction and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Huntley preserved appeal of suppression denial | Huntley | Huntley | Not preserved; court lacks jurisdiction to review. |
| Whether the obstruction of justice enhancement § 3C1.1 applies | Huntley | Huntley | District court properly applied the enhancement. |
Key Cases Cited
- United States v. Horn, 113 F. App’x 355 (10th Cir. 2004) (contact suggested but not substantial step toward perjury)
- United States v. Bingham, 81 F.3d 617 (6th Cir. 1996) (substantial step to obstruct justice via witness coercion)
- United States v. Bazazpour, 690 F.3d 796 (6th Cir. 2012) (standard for review of obstruction of justice enhancement)
- United States v. Gilpatrick, 548 F.3d 479 (6th Cir. 2008) (clear error/de novo mix for obstruction analysis)