United States v. Stubblefield
395 U.S. App. D.C. 377
D.C. Cir.2011Background
- Stubblefield was convicted of six bank robberies and one attempted bank robbery in 2008 in the Washington, D.C. area based largely on eyewitness identifications.
- Witnesses described the robber as a very short African-American male with facial indentations and a raspy voice across multiple incidents.
- The government also introduced evidence of an uncharged Virginia bank robbery to identify the robber's identity.
- Stubblefield challenged fingerprint analysis and argued eyewitness identifications were unreliable; the defense presented alternative descriptions from some witnesses.
- The indictment followed a May 13, 2008 complaint; 31 days elapsed until the June 13, 2008 indictment, with May 23 excluded as a pretrial-motion delay.
- The district court admitted the Virginia 404(b) evidence; the jury convicted on all counts, and Stubblefield appeals three trial- and evidence-related issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Speedy Trial Act timing | Stubblefield: indictment untimely under 3162(a)(1). | Government: 3161(h)(1)(D) excludes delay due to pretrial motions; May 23 is excluded. | Indictment timely; exclusion applies automatically. |
| Closing argument scope | Stubblefield: defense should argue best practices and DNA superiority. | Government: no evidence of best practices; improper to premise on unproven facts. | No abuse; arguments properly limited; defense permitted reasonable inferences. |
| Admissibility of uncharged Virginia robbery evidence | Stubblefield: 404(b) evidence only supports propensity; prejudicial. | Government: used for identity; admissible under 404(b). | Harmless error; no substantial prejudice to verdict. |
Key Cases Cited
- United States v. Garrett, 720 F.2d 705 (D.C. Cir. 1983) (automatic §3161(h)(1)(D) exclusion for pretrial motions)
- United States v. Tinklenberg, 131 S. Ct. 2007 (Supreme Court 2011) (automatic delays under §3161(h)(1)(D) without court findings)
- Bloate v. United States, 130 S. Ct. 1345 (U.S. 2010) (automatic §3161(h)(1)(D) exclusion without findings)
- United States v. Johnson, 519 F.3d 478 (D.C. Cir. 2008) (harmless-error standard for non-constitutional 404(b) error)
- Kotteakos v. United States, 328 U.S. 750 (U.S. 1946) (prejudice standard for 404(b) considerations)
- Pettiford v. United States, 517 F.3d 584 (D.C. Cir. 2008) (limiting instructions and 404(b) balancing)