United States v. Ruben Ceja-Rangel
688 F. App'x 203
| 4th Cir. | 2017Background
- Defendant Ruben Ceja-Rangel was tried and convicted by a jury for crimes arising from a kidnapping; his first trial ended in a mistrial. The appeal follows a conviction after retrial.
- Pretrial, Ceja moved to suppress (a) an out-of-court photographic identification and (b) physical evidence (a firearm and police badge) allegedly discovered via a codefendant who did not testify. He also moved to exclude references to a cartel/Mexican drug trafficking organization and to exclude the victim’s proffer agreement with the Government.
- At trial the victim identified Ceja from photographs and testified about his abduction; the Government introduced the victim’s proffer agreement and elicited testimony about a possible cartel connection (victim’s claim). Ceja was arrested fleeing the house where the victim was held.
- Ceja raised Brady and due-process claims on appeal, alleging the Government suppressed the victim’s plea/proffer agreement and knowingly allowed false or inconsistent testimony to stand. He also alleged prosecutorial misconduct in closing (vouching, calling the defense a sham, and improper references to immigration status).
- The district court denied Ceja’s suppression and exclusion motions, admitted the proffer with limiting instructions, and the jury convicted. The Fourth Circuit reviewed suppression findings (factual for clear error; legal issues de novo) and prosecutorial-misconduct claims under plain-error review.
Issues
| Issue | Ceja's Argument | Government's Argument | Held |
|---|---|---|---|
| Photo-ID admissibility | Photo lineup was impermissibly suggestive; ID should be suppressed | Even if suggestive, the ID was reliable under Biggers factors | Identification reliable; admission proper |
| Physical evidence (firearm/badge) & Confrontation Clause | Evidence derived from non-testifying codefendant triggers Confrontation problems | Physical items are not testimonial; Confrontation Clause inapplicable | Admission proper; no Confrontation Clause violation |
| References to cartel/ethnicity | References injected improper ethnic stereotype and prejudiced jury | Victim testified cartel involvement; references limited and cross-examination remedy existed | No abuse of discretion; any error harmless |
| Admission of victim’s proffer agreement | Agreement unfairly bolstered victim’s credibility; should be excluded | Proffer admitted with limits and jury instruction; Government did not vouch for truthfulness | Admission not an abuse of discretion; instruction and limited use cured concerns |
| Brady suppression claim | Government failed to disclose victim’s plea agreement and related documents | No evidence agreement existed before trial; plea occurred after testimony; no suppression | No Brady violation shown |
| Government’s use of alleged false/testimony | Government knowingly used or failed to correct materially false testimony | Inconsistencies do not prove knowing use of perjury; cross-examination addressed them | No plain error; no showing of knowing use of false testimony |
| Prosecutorial misconduct in closing | Prosecutor vouched, called defense a sham, and invoked immigration status unfairly | Arguments were based on trial record; immigration remark invited by Ceja’s closing; any error harmless | No reversible prosecutorial misconduct; remarks permissible or harmless |
Key Cases Cited
- United States v. Lull, 824 F.3d 109 (4th Cir. 2016) (standard of review for suppression rulings)
- Perry v. New Hampshire, 565 U.S. 228 (2012) (due process concerns arise when identification procedures are suggestive and unnecessary)
- United States v. Saunders, 501 F.3d 384 (4th Cir. 2007) (two-step test for photo identification challenge and reliability inquiry)
- Neil v. Biggers, 409 U.S. 188 (1972) (factors to assess reliability of identifications)
- Crawford v. Washington, 541 U.S. 36 (2004) (Confrontation Clause bars testimonial out-of-court statements absent prior cross-examination)
- United States v. Henderson, 717 F.2d 135 (4th Cir. 1983) (admission of plea/proffer evidence and factors for limiting jury impact)
- United States v. Garcia-Lagunas, 835 F.3d 479 (4th Cir. 2016) (impropriety of injecting ethnicity or immigration status into trial)
- United States v. Catone, 769 F.3d 866 (4th Cir. 2014) (plain-error standard on appellate review for unpreserved challenges)