United States v. Taylor
289 F. Supp. 3d 55
| D.C. Cir. | 2018Background
- Taylor was arrested during a June 1, 2017 eviction where officers found an AR-15, two handguns, magazines, ammunition, and two vials later tested as PCP; he was indicted on drug and firearm charges including a §924(c) count.
- A magistrate judge ordered Taylor detained pending trial, invoking the statutory presumption of dangerousness triggered by the drug and §924(c) charges.
- At the suppression proceedings the government conceded Taylor’s alleged custodial admission (that the items belonged to him) must be suppressed under Miranda; other suppression hearing testimony raised questions about whether some contraband was in another occupant’s bedroom.
- Taylor moved under 18 U.S.C. §3145(b) to revoke the detention order; the district court conducted a de novo review and heard additional evidence and argument about the lab chemist misconduct and the strength of the government’s constructive-possession theory.
- The district court concluded Taylor met his burden of production to rebut (but not “burst”) the presumption, held that suppressed statements should be disregarded for the §3142(g)(2) “weight of the evidence” factor but may be considered under §3142(g)(4) (danger), and ultimately granted release under strict conditions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Taylor rebutted the statutory presumption of dangerousness | Taylor: new evidence (living arrangements, employment offer, suppression rulings undermining incriminating statements) rebuts the presumption | Government: indictment and prior hearing facts (including alleged admission) sustain the presumption | Court: Taylor met burden of production to rebut the presumption (presumption remains a factor but does not control) |
| Whether suppressed custodial statements may be considered under §3142(g)(2) (weight of the evidence) | Taylor: suppressed statements should not be considered when assessing weight of the evidence | Government: may consider such statements to assess likelihood of conviction and danger | Court: suppressed evidence should be disregarded or given diminished weight for §3142(g)(2); reevaluation required without the admission |
| Whether suppressed custodial statements may be considered under §3142(g)(4) (nature/seriousness of danger) | Taylor: Miranda suppression precludes reliance at detention stage | Government: court may consider all reliable information for danger assessment | Court: §3142(f) permits consideration of otherwise inadmissible evidence for danger; un‑Mirandized statements may be considered absent evidence of involuntariness or misconduct |
| Whether continued detention was warranted on clear and convincing evidence | Taylor: weakened government case, lack of recent violent history, and available strict conditions support release | Government: serious charged offenses, weapons and drugs present, prior convictions justify detention | Court: on balance government failed to meet clear and convincing standard; ordered release under stringent conditions (high‑intensity supervision, home confinement, no firearms/ammo/drugs, testing, no contact with witnesses) |
Key Cases Cited
- United States v. Stone, 608 F.3d 939 (6th Cir. 2010) (discusses weight-of-evidence factor and detention presumption)
- United States v. Alatishe, 768 F.2d 364 (D.C. Cir. 1985) (explains presumption is rebuttable but remains a factor)
- United States v. Jessup, 757 F.2d 378 (1st Cir. 1985) (discusses presumption and burden of production)
- United States v. Mercedes, 254 F.3d 433 (2d Cir. 2001) (presumption does not shift burden of persuasion)
- United States v. Smith, 79 F.3d 1208 (D.C. Cir. 1996) (indictment alone establishes probable cause to trigger the presumption)
- United States v. Peralta, 849 F.2d 625 (D.C. Cir. 1988) (detention/release may be revisited after suppression rulings that affect likelihood of conviction)
- Salerno v. United States, 481 U.S. 739 (1987) (constitutional standard: government must show by clear and convincing evidence no conditions will assure community safety)
- United States v. Dorman, 860 F.3d 675 (D.C. Cir. 2017) (constructive possession elements for shared-space contraband)
- United States v. Littlejohn, 489 F.3d 1335 (D.C. Cir. 2007) (possession/guilt standards for constructive possession)
- United States v. Singleton, 182 F.3d 7 (D.C. Cir. 1999) (felon-in-possession not categorically a crime of violence)