United States v. Tyreek Styles
659 F. App'x 79
| 3rd Cir. | 2016Background
- Five men, including Tyreek Styles, robbed a home after midnight on Dec. 3, 2011; victims were forced to move within the house, assaulted, and money, a phone, and cards were taken; a shot was fired as robbers fled.
- Officers found a gold Chevy Malibu registered to Styles near the scene; later searched and recovered items linking Styles to a co-conspirator and the robbery (resume, letter, gloves, matching fabric, phone receipt).
- A Ruger with one spent round and cash was found near where Tyrone Styles jumped from a bridge; ballistics matched the spent round to a bullet recovered from a neighbor’s ceiling.
- DNA on the stun gun and cloth matched Tyreek Styles; cell records showed contact between Styles and co-defendant Jeremiah Stokes around the time of the robbery.
- Styles was convicted of conspiracy to commit Hobbs Act robbery, one Hobbs Act robbery count, and a § 924(c) firearms offense; district court applied enhancements for serious bodily injury, abduction (+4), and obstruction of justice (+2), producing a 240-month sentence.
- On appeal, the Third Circuit affirmed convictions, upheld the abduction enhancement, but agreed the obstruction enhancement was improper and remanded for resentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence supported conviction under 18 U.S.C. § 924(c) (advance knowledge of a gun) | Government: coconspirators discussed and packed the gun; witnesses described transfer of the gun en route, supporting advance knowledge | Styles: no proof he knew a gun would be used | Held: Sufficient evidence; jury could infer advance knowledge (affirmed) |
| Whether evidence supported conspiracy and Hobbs Act robbery convictions | Government: witness testimony (Stokes, Tyrone), DNA, car location, items in car, cell records, and flight supported active participation | Styles: at most a knowing spectator, insufficient proof of membership in conspiracy or participation | Held: Evidence sufficient to sustain conspiracy and robbery convictions (affirmed) |
| Whether the four-level abduction enhancement (U.S.S.G. §2B3.1(b)(4)(A)) was properly applied | Government: victims were forced to move within house, accompanied by robbers, to facilitate robbery | Styles: he didn’t personally restrain moved victims; movement not necessary to access house; typical robbery conduct | Held: Enhancement proper—moving victims within house by force to facilitate robbery satisfies criteria (affirmed) |
| Whether two-level obstruction enhancement (U.S.S.G. §3C1.1) was proper | Government (at sentencing): Styles made false statements to police warranting enhancement; on appeal government concedes enhancement was improper | Styles: statements did not materially impede investigation; he voluntarily gave phone, code, and DNA | Held: Enhancement improper—statements did not significantly obstruct investigation; remand for resentencing (vacate sentence) |
Key Cases Cited
- Rosemond v. United States, 134 S. Ct. 1240 (2014) (advance knowledge requirement for § 924(c))
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)
- United States v. Reynos, 680 F.3d 283 (3d Cir.) (abduction enhancement applicable where victims moved within single structure)
- United States v. Caraballo–Rodriguez, 726 F.3d 418 (3d Cir. 2013) (standard for de novo review of Rule 29 motions)
- United States v. Booth, 432 F.3d 542 (3d Cir. 2005) (binding effect of Guidelines application notes)
- United States v. Wright, 642 F.3d 148 (3d Cir. 2011) (incorrect Guidelines computation is procedural error requiring resentencing)