United States v. Williams
2013 U.S. App. LEXIS 9936
1st Cir.2013Background
- Defendant Kareem Williams, a thrice-convicted felon, was charged with possessing a firearm as a felon and with possessing a firearm with an obliterated serial number, based on events around a June 2011 arrest after a car stop.
- Two cars were stopped; a firearm-loaded trunk was found in the Maxima near a pass-through to the back seat; Williams was in the Maxima and did not immediately comply with commands.
- After arrest, Williams waived Miranda rights and provided statements admitting knowledge of a planned robbery involving guns and describing guns at a cookout earlier that night.
- The guns were traced to interstate commerce, and one firearm had an obliterated serial number; Williams conceded prior felony status and the interstate travel of the guns.
- The government sought to prove knowing possession by circumstantial evidence, including the gun’s location, Williams’s behavior during the stop, and his statements.
- The district court admitted Williams’s statements about the robbery and the cookout; the jury convicted, and Williams was sentenced as an armed career criminal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was sufficient evidence of knowing possession | Williams | Williams | Affirmed; evidence supported knowing possession |
| Whether admission of Williams's statements was proper evidence | Government | Williams | Affirmed; statements relevant to knowledge and motive |
| Whether the district court erred in applying Rule 403 balancing to the statements | Government | Williams | Not reversible plain error; no abuse of discretion |
| Whether the limiting instruction adequately mitigated potential unfair prejudice | Williams | Williams | Not plain error; instruction adequate |
Key Cases Cited
- United States v. Walker, 665 F.3d 212 (1st Cir. 2011) (standard for sufficiency review in circumstantial evidence)
- United States v. Troy, 618 F.3d 27 (1st Cir. 2010) (constructive possession framework and evidentiary review)
- United States v. Echeverri, 982 F.2d 675 (1st Cir. 1993) (plausible rendition of the record required for sufficiency)
- United States v. Dwinells, 508 F.3d 63 (1st Cir. 2007) (de novo review of denial of judgment of acquittal)
- United States v. Robinson, 473 F.3d 387 (1st Cir. 2007) (constructive possession evidence; access and opportunity)
- United States v. Liranzo, 385 F.3d 66 (1st Cir. 2004) (constructive possession by front-seat passenger)
- United States v. Chapdelaine, 989 F.2d 28 (1st Cir. 1993) (circumstantial evidence and possession inference)
- United States v. Meadows, 571 F.3d 131 (1st Cir. 2009) (evidence linking motive and knowledge to possession)
- United States v. Powell, 50 F.3d 94 (1st Cir. 1995) (Rule 404(b) framework for probative value and prejudice)
- United States v. Rodríguez-Estrada, 877 F.2d 153 (1st Cir. 1989) (probative value of prior acts under limiting instruction)