United States v. Williams, 878 F. Supp. 2d 190

Maurice Williams faces three suppression motions (two vehicle searches and one oral statement) and a Rule 404(b) motion concerning uncharged conduct; a suppression hearing was held July 3, 2012.
Surveillance of 5318 9th Street NW began September 16, 2011 after narcotics complaints and undercover transactions were observed at the residence.
On October 21, 2011, Maurice Williams, driving a white Chevrolet Traverse, was stopped for a seatbelt/permit issue; odor of marijuana was detected and 125 grams of cocaine plus 4 grams of marijuana were found in the vehicle after a traffic stop.
On February 1, 2012, Williams was arrested on a bench warrant; later, a warrantless search of his car—relating to the same narcotics investigation—led to seizure of narcotics aided by a drug-sniffing dog; the government seeks to admit related evidence under Rule 404(b).
The court preliminarily concluded that the October 2011 stop and search were lawful, the February 2012 search was supported by the automobile exception and probable cause, the February 2012 statement was Miranda-protected and must be suppressed, and the 404(b) evidence regarding uncharged narcotics is admissible.
The memorandum culminates in an order denying the October 21, 2011 suppression, denying the February 1, 2012 suppression, granting suppression of the “dropped off” statement, and granting the 404(b) motion as to Maurice Williams.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the October 21, 2011 stop was lawful under the Fourth Amendment.	United States: stop supported by observable seatbelt violation and license status.	Williams: disputed seatbelt status; stop may have been pretextual; objective reasonableness governs.	Stop valid; seizure/search permissible under Fourth Amendment.
Whether the February 1, 2012 vehicle search was valid under the automobile exception.	United States: probable cause plus odor of marijuana and linkage to Williams via key fob.	Williams: challenged linkage and temporal aspects; search improper without independent probable cause.	Search valid under automobile exception; probable cause established.
Whether evidence of uncharged narcotics from the February 1, 2012 search is admissible under Rule 404(b).	United States: uncharged conduct relevant to knowledge/intent; similar narcotics involved.	Williams: risk of unfair prejudice; unfairly prejudicial to trial.	Admissible under Rule 404(b) after balancing probative value against prejudice; probative weight substantial.
Whether the statement that Williams was “dropped off” at the police station was admissible given Miranda protections.	Government: booking-question exception may apply.	Statement obtained before Miranda warnings; not within booking exception; suppressible.	Statement suppressed; Miranda custodial/interrogation requirements triggered.

United States v. Whren, 517 U.S. 806 (U.S. 1996) (probable-cause stop governs; subjective motive irrelevant)
United States v. Ross, 456 U.S. 798 (U.S. 1982) (scope of warrantless automobile search defined by object of search)
Hill v. United States, 131 F.3d 1056 (D.C. Cir. 1997) (objectively reasonable belief supports stop despite possible mistake of law)
United States v. Edmonds, 240 F.3d 55 (D.C. Cir. 2001) (furtive gestures can contribute to reasonable suspicion; context matters)
United States v. Turner, 119 F.3d 18 (D.C. Cir. 1997) (smell of marijuana supports probable cause to search vehicle)
United States v. Bowie, 232 F.3d 923 (D.C. Cir. 2000) (Rule 404(b) evidence admissible to show knowledge/intent when probative and not unduly prejudicial)