United States v. Starks, Jr.
769 F.3d 83
1st Cir.2014Background
- Starks was driving a rental car in Massachusetts when a state trooper observed traffic deviations and a color discrepancy in the car’s registration.
- A license check revealed Starks’s license was suspended; he was arrested for driving on a suspended license and frisked, revealing pills.
- In the car’s front seat, the officer saw a translucent bag containing a handgun, ammunition, and other items, leading to a federal felon-in-possession charge.
- Starks moved to suppress all evidence as fruits of an unlawful stop, arguing lack of standing and potential racial profiling; the district court denied standing.
- At trial, multiple motions in limine targeted third-party statements and Rodriguez’s statements; the court denied several of these motions.
- Starks was convicted and sentenced to 210 months; on appeal, the First Circuit vacated the conviction and remanded for an evidentiary hearing on standing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing to challenge the stop | Starks had Fourth Amendment standing as an interested occupant of the vehicle. | Starks, as an unauthorized, unlicensed driver, had no reasonable privacy expectation and thus no standing. | Standing exists; remand for new suppression hearing. |
| Prosecutorial conduct in closing | Closing misstated the district court’s ruling on the stop’s legality and improperly urged the jury. | Not detailed in held ruling; focus remains on standing; potential error noted but not decided. | Not reached due to remand on standing; issue acknowledged as potentially improper. |
| Evidence and impeachment rulings | Court curtailed impeachment of Trooper Vital and excluded Rodriguez’s statements and background. | Rodriguez’s statements and related materials were admissible under trustworthiness or motive rules. | Rulings reviewed but not reached on the merits; remand required. |
| Juror bias and voir dire | Juror had undisclosed acquaintance with Starks’s son affecting impartiality. | Voir dire disclosure issue undermined impartiality; potential juror bias claim. | Not addressed on the merits; remand to address standing first. |
Key Cases Cited
- Brendlin v. California, 551 U.S. 249 (U.S. 2007) (passenger seizure and standing in stop)
- United States v. Werra, 638 F.3d 326 (1st Cir. 2011) (de novo review of standing ruling)
- United States v. Reynolds, 646 F.3d 63 (1st Cir. 2011) (plain-error review for unraised suppression arguments)
- United States v. Symonevich, 688 F.3d 12 (1st Cir. 2012) (passenger standing to challenge search)
- United States v. Monserrate-Valentín, 729 F.3d 31 (1st Cir. 2013) (meaningful corroboration for admissibility of statements)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (equal protection basis for challenging discriminatory enforcement)
- United States v. Powers, 702 F.3d 1 (1st Cir. 2012) (evidentiary rulings and impeachment standards)
- United States v. Bartelho, 129 F.3d 663 (1st Cir. 1997) (trustworthiness and corroboration considerations for out-of-court statements)