US v. Medley: Medley was arrested in the District of Columbia after being found in possession of two firearms and was eventually charged in the District with being a felon in possession of a firearm and appointed counsel. Weeks later, officers in Maryland investigating a carjacking learned that the shells from the scene of that offense matched one of the guns Medley had possessed. The Maryland officers went to the District and questioned Medley, without counsel, who made inculpatory statements related to the firearms he possessed. He was then charged federally in Maryland with carjacking, using a firearm during a crime of violence, and being a felon in possession of a firearm. After unsuccessfully moving the suppress the statements, Medley was convicted at trial of the felon-in-possession charge, but acquitted of the other charges. Nonetheless, the district court enhanced Medley for possessing the firearm in connection with another felony offense (the carjacking) and imposed a Guideline sentence of 78 months in prison.
Medley challenged both his conviction and sentence on appeal, both of which the Fourth Circuit affirmed. As to the conviction, Medley reiterated his argument that his statements to the Maryland officers should have been suppressed because they were taken in violation of his right to counsel and the federal felon-in-possession charge was the “same offense” as the charge in the District for which counsel had been appointed. Ultimately, the court concluded it did not need to resolve that issue, as “Medley waived his right because he never made a clear, unambiguous assertion of the right to counsel after receiving his Miranda warnings.” As to sentencing, the court rejected Medley’s challenge to the use of acquitted conduct and concluded that the district court did not clearly error in concluding that he committed the carjacking and applying the sentencing enhancement.
No comments:
Post a Comment