Wednesday, February 05, 2014

"Closely related" law provides reasonable suspicion

US v. Williams:  Leconie Williams, IV, received two firearms charges after police stopped his vehicle for violating the section of Maryland’s traffic code that prohibits leaving a vehicle in the street in a manner that obstructs traffic.  Mr. Williams filed a motion to suppress the evidence discovered as a result of the stop, arguing that police lacked probable cause.  The district court denied the motion because it found that the police had reasonable suspicion that Mr. Williams violated a different, but closely related, section of the Maryland traffic code.  The government moved to exclude evidence of earlier alleged police misconduct by the officers involved in this case.

After an initial mistrial in which Mr. Williams was acquitted of one count and the jury could not reach a decision on the second count, a second jury found Mr. Williams guilty on one count.  On appeal, Mr. Williams challenged the district court’s decision to deny his motion to suppress, as well as the decision to exclude evidence of earlier alleged incidents of police misconduct.

The Fourth Circuit panel determined that the Maryland traffic code section listed on the citation given to Mr. Williams could not be the basis for conducting the stop of Mr. Williams’ car.  It upheld the district court’s decision to deny the motion to suppress because “the conduct that [the officer] McCann set forth as the basis for the stop was plainly illegal under Maryland law, albeit in a different section than the one in the traffic citation.” Further, the panel stated that Mr. Williams failed to show that the district court clearly erred in finding that he had stopped his vehicle in the middle of the road, conduct which violates some provision of the Maryland traffic code, just not the one the police cited.

With regard to the evidence of earlier incidents of alleged police misconduct by the officers involved in this case, Mr. Williams wanted to admit evidence of misconduct from three civil suits containing allegations of misdeeds by the police officers who arrested him; the government moved to exclude this evidence.  Unfortunately for Mr. Williams, it appears the age of the evidence, dating back more than ten years, gave the district court an easy reason to find little probative value in this evidence and exclude it.  The Fourth Circuit did not find the exclusion “irrational.”

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