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United States v. Ikea Gartrell
25-3048
D.C. Cir.
Jun 12, 2025
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Case Information

*1 United States Court of Appeals

F OR T HE D ISTRICT OF C OLUMBIA C IRCUIT

____________ No. 25-3048 September Term, 2024

1:25-cr-00084-RBW-1 Filed On: June 12, 2025

United States of America,

Appellee

v.

Ikea Jovaun Gartrell,

Appellant BEFORE: Katsas, Rao, and Walker, Circuit Judges

J U D G M E N T

This appeal was considered on the record from the United States District Court and the memoranda of law and fact filed by the parties. The court has determined that the issues presented occasion no need for an opinion. See D.C. Cir. Rule 36. Upon consideration of the foregoing, it is

ORDERED AND ADJUDGED that the district court’s pretrial detention orders entered on April 9 and 14, 2025, be affirmed.

Appellant asserts that the district court improperly made its own findings regarding detention, rather than reviewing the magistrate judge’s findings for clear error. As appellant does not respond to appellee’s argument that this court reviews the matter only for plain error, she has forfeited any objection to that argument. See United States ex rel. Totten v. Bombardier Corp., 380 F.3d 488, 497 (D.C. Cir. 2004). Moreover, she has not shown plain error, given the numerous decisions from other circuits endorsing de novo review by the district court in this context. See generally United States v. Winstead, 890 F.3d 1082, 1088 (D.C. Cir. 2018).

As for the district court’s findings, the court did not rely on a presumption of detention or clearly err in concluding, after reviewing the factors set forth in 18 U.S.C. § 3142(g) and the information presented at the detention hearing, that the government had proven by clear and convincing evidence that no condition or combination of conditions of release would reasonably assure the safety of any other person and the community. See generally United States v. Hale-Cusanelli, 3 F.4th 449, 454-55 (D.C. Cir. 2021). The relevant considerations included appellant’s possession of a loaded firearm, the weight of the evidence against her, and her record of felony convictions.

United States Court of Appeals

F OR T HE D ISTRICT OF C OLUMBIA C IRCUIT

____________ No. 25-3048 September Term, 2024

Pursuant to D.C. Circuit Rule 36, this disposition will not be published. The Clerk is directed to withhold issuance of the mandate herein until seven days after resolution of any timely petition for rehearing or petition for rehearing en banc. See Fed. R. App. P. 41(b); D.C. Cir. Rule 41.

Per Curiam

FOR THE COURT: Clifton B. Cislak, Clerk BY: /s/ Daniel J. Reidy Deputy Clerk 2

Case Details

Case Name: United States v. Ikea Gartrell
Court Name: Court of Appeals for the D.C. Circuit
Date Published: Jun 12, 2025
Docket Number: 25-3048
Court Abbreviation: D.C. Cir.
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