Watson v. United States
2012 D.C. App. LEXIS 156
| D.C. | 2012Background
- Watson was convicted of attempted possession of marijuana in the DC Superior Court; conviction upheld on appeal.
- Officer used Lidar III to claim Watson drove 88 mph on a DC bridge, leading to a traffic stop/arrest for speeding over 30 mph over limit.
- Marijuana and other substances were found in Watson’s sock during a frisk; Watson made statements challenged as Miranda violations.
- The trial court admitted Watson’s statements and relied on them to convict; Watson appealed asserting suppression and Miranda errors.
- The appellate court reviewed suppression and Miranda rulings de novo, upholding the trial court’s determinations and affirming the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to arrest for speeding over limit | Watson | Watson argues Lidar device and visual estimate lacked probable cause | Probable cause supported; device calibration and officer training credibly show reasonable belief Watson was speeding. |
| Rule 16 discovery materiality for suppression | Watson | Watson asserts missing calibration/training documents were material | No abuse of discretion; documents produced sufficed; remaining materials not material to suppression issue. |
| Public safety Miranda exception applicability | Watson | Public safety exception justifies questioning about the bulge | Public safety exception applicable to initial question about the bulge; not a broader interrogation. |
| Spontaneous statement admissibility after arrest | Watson | Spontaneous remark about buying for girlfriend admissible | Statement admissible as spontaneous, not the product of custodial interrogation. |
Key Cases Cited
- United States v. Quarles, 467 U.S. 649 (1984) (public safety exception to Miranda applies when safety concerns exist)
- Rhode Island v. Innis, 446 U.S. 291 (1980) (definition of interrogation; statements elicited by police with coercive objective)
- Ornelas v. United States, 517 U.S. 690 (1996) (probable-cause review; totality of circumstances standard)
- Perkins v. United States, 936 A.2d 303 (D.C.2007) (probable cause requires reasonably trustworthy information to warrant arrest)