Justia District of Columbia Court of Appeals Opinion Summaries

In October 2022, a man crashed his car into a parked vehicle in southeast Washington, D.C. After the collision, the car’s owner confronted him, and as police arrived, the man fled on foot. Officers pursued and apprehended him, discovering a gun with a large-capacity magazine under a vehicle along his escape route and another large-capacity magazine with ammunition inside his car. He was charged with several firearm-related offenses, including possession of a large-capacity ammunition feeding device and unlawful possession of ammunition.The Superior Court of the District of Columbia denied the defendant’s motions to dismiss the large-capacity magazine charges on Second Amendment grounds and to suppress the evidence found at the scene, ruling that the search and seizure were justified. After a jury trial, he was convicted of one count of possession of a large-capacity ammunition feeding device and one count of unlawful possession of ammunition, both based on the magazine found in his car. He was acquitted of other charges. The defendant appealed, challenging the denial of suppression, the sufficiency of the evidence for the large-capacity magazine conviction, the lack of a jury instruction on knowledge, and the constitutionality of the statute.The District of Columbia Court of Appeals reviewed the case. After oral argument, the government moved to vacate the large-capacity magazine conviction due to a change in its position on the statute’s constitutionality, which the court granted. The court affirmed the denial of suppression and upheld the unlawful possession of ammunition conviction, holding that the officers’ entry into the car to seize the magazine was justified under the automobile exception to the warrant requirement, as they had probable cause to believe the car contained evidence of criminal activity. The case was remanded for further proceedings. View "Miller v. United States" on Justia Law

A woman was carjacked at gunpoint while filling her car at a gas station in Southeast D.C. The assailant, a stranger to her, wore a hood and brandished a gun, demanding her car keys. She focused mainly on the weapon during the brief encounter, only glancing at his face at the very end. Several hours later, police arrested Andrew Patrick driving her stolen vehicle about four miles away. Officers called the victim to the scene, where Patrick was handcuffed and positioned next to her car, flanked by police. She identified him as her assailant during two drive-by show-up procedures and later in court.The case was tried in the Superior Court of the District of Columbia. Patrick moved to suppress the victim’s identifications, arguing the show-up procedures were highly suggestive and unnecessary, given that he was already under arrest and a lineup or photo array could have been used. The trial court denied the motion, finding the procedures were not unduly suggestive and that the identifications were reliable, citing the victim’s opportunity to observe the assailant and her certainty.On appeal, the District of Columbia Court of Appeals reviewed whether admitting the identifications violated Patrick’s due process rights. The court held that the show-up procedures were extraordinarily and unnecessarily suggestive, as Patrick was already under arrest and there was no urgency requiring a show-up. The identifications lacked independent indicia of reliability, given the victim’s limited opportunity to observe the assailant and her generic description. The court found constitutional error in admitting the identifications and reversed Patrick’s convictions for armed carjacking and possession of a firearm during a crime of violence, but affirmed his other weapons-related convictions, finding those were not impacted by the identifications. View "Patrick v. United States" on Justia Law

A man was convicted by a jury of several offenses related to a shooting outside a nightclub in Washington, D.C. in July 2021. The evidence showed that the defendant, who was twenty years old at the time, shot another individual and then hid the firearm. He was identified by a witness, and DNA evidence linked him to the recovered handgun. The defendant initially told police he was not the shooter, but at trial, he admitted to firing the gun, claiming self-defense.Prior to trial in the Superior Court of the District of Columbia, the defendant moved to dismiss charges related to carrying a pistol without a license, possession of an unregistered firearm, and unlawful possession of ammunition. He argued that the District’s laws, which require individuals to be at least twenty-one years old to obtain a firearm registration or license, violated the Second Amendment, especially in light of the Supreme Court’s decision in New York State Rifle & Pistol Association, Inc. v. Bruen. The trial court denied the motion, finding the age-based restrictions consistent with the Second Amendment and historical firearm regulation. At trial, the government impeached the defendant’s credibility by highlighting inconsistencies between his initial statements and his trial testimony. The jury convicted him on all counts.On appeal, the District of Columbia Court of Appeals reviewed the constitutionality of the District’s age-based firearm registration and licensing statutes and the propriety of the government’s arguments regarding the defendant’s credibility. The court held that the age-based statutes are constitutional because they are consistent with the nation’s historical tradition of firearm regulation. The court also found that the government’s arguments about the defendant’s change in defense theory were not improper. The court affirmed the convictions but remanded for the limited purpose of merging certain convictions and resentencing as necessary. View "Picon v. United States" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

Police received reports of a group committing robberies or attempted robberies in a white Nissan Rogue that had been reported stolen. Officers tracked the vehicle, observed it being driven recklessly, and saw it crash. Four individuals, including E.A., fled from the car. E.A. was apprehended shortly after the crash, frisked, and found to have a handgun in his sweatshirt pocket. He was subsequently charged with carrying a pistol without a license and possession of an unregistered firearm.The Superior Court of the District of Columbia denied E.A.’s motion to suppress the handgun, finding that officers had reasonable articulable suspicion to stop and frisk him based on his association with the group suspected of recent robberies and the stolen vehicle, as well as his flight from the crash. The court also concluded that, even if the officers’ actions exceeded the scope of a Terry stop, they had probable cause to arrest E.A. for multiple offenses, justifying a search incident to arrest. E.A. was adjudicated delinquent on both firearms charges and appealed, challenging the denial of his suppression motion.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the officers had reasonable articulable suspicion to stop and frisk E.A., relying on the collective knowledge from radio dispatches, corroborated by officers’ observations and the circumstances of the stop. The court further held that the officers’ use of handcuffs and drawn weapons did not convert the stop into an arrest, given the safety concerns and flight risk. Therefore, the search and seizure of the handgun did not violate the Fourth Amendment, and the judgment was affirmed. View "In re E.A." on Justia Law

A group of ten Black men, including the appellant, were conversing on a sidewalk in Ward Four of the District of Columbia when four officers from the Metropolitan Police Department’s Gun Recovery Unit approached them as part of a firearm interdiction operation. The officers, wearing tactical vests and displaying police equipment, approached the group without any specific suspicion of criminal activity. One officer, DelBorrell, approached the appellant from behind and asked if he was carrying a firearm. The appellant denied it and twice lifted his shirt to show his waistband. The officer then asked the appellant to “hike” his pants up, which he did. Another officer then noticed a bulge in the appellant’s groin area, believed it to be a firearm, and after a brief struggle, the officers recovered a gun from the appellant’s pants.The appellant was charged with eight firearm-related offenses. He moved to suppress the firearm and a subsequent statement, arguing they were the result of an unreasonable seizure in violation of the Fourth Amendment. The Superior Court of the District of Columbia denied the motion, finding that the appellant was not seized until after he raised his pants, at which point the officers had reasonable suspicion based on the observed bulge. The appellant was convicted on all counts following a trial on stipulated facts and appealed.The District of Columbia Court of Appeals reviewed the case and held that the appellant was seized within the meaning of the Fourth Amendment when the officer requested that he raise his pants. The court found that, considering the officers’ show of authority, the accusatory and repetitive questioning, and the appellant’s status as a Black man in a highly policed area, a reasonable person in his position would not have felt free to leave. Because the seizure was not supported by reasonable suspicion or probable cause, it was unreasonable. The court vacated the convictions and remanded for further proceedings. View "Carter v. United States" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

The case involves a dispute within the Unification Church, also known as the Unification Movement, following a schism and succession conflict. The plaintiffs, including the Family Federation for World Peace and Unification International, filed a complaint in 2011 against defendants, including Unification Church International (UCI) and its president, Hyun Jin (Preston) Moon. The plaintiffs alleged that the defendants engaged in actions contrary to the church's mission, including amending UCI's articles of incorporation and transferring assets to entities like the Kingdom Investments Foundation (KIF) and the Global Peace Foundation (GPF).The Superior Court of the District of Columbia initially granted partial summary judgment in favor of the plaintiffs, finding that the defendants' actions were inconsistent with UCI's original purposes. However, the court's decision was reversed on appeal in Moon III, where it was held that resolving the plaintiffs' claims would require deciding disputed religious questions, making them nonjusticiable under the First Amendment's religious abstention doctrine. The case was remanded for further proceedings.On remand, the trial court dismissed the remaining claims with prejudice. The court found that the plaintiffs lacked special interest standing to pursue their self-dealing claims against Preston Moon after Moon III, as the claims no longer involved extraordinary measures threatening UCI's existence. The court also determined that the contract claims were nonjusticiable under the religious abstention doctrine, as resolving them would require interpreting religious terms and doctrines. The court declined to apply the potential fraud or collusion exception to the religious abstention doctrine, finding no evidence of bad faith for secular purposes.The District of Columbia Court of Appeals affirmed the trial court's orders, agreeing that the plaintiffs' claims were nonjusticiable and that they lacked special interest standing. The court also upheld the trial court's decision to deny the plaintiffs' motion to reopen discovery, finding no abuse of discretion. The litigation, which spanned over a decade, was thereby brought to a close. View "Family Federation for World Peace and Unification International v. Moon" on Justia Law

Rubin Delphonso Holman was convicted of robbery, assault with intent to rob (AWIR), and simple assault. The incident occurred on a Metro train where Holman and his friend, Mr. Black, engaged in inappropriate behavior towards Domini Dotson. After Dotson moved to another train car and reported the incident, Holman followed her, threatened her, and attempted to take her phone. When Dotson resisted, Holman assaulted her, and during the altercation, he took her phone. Holman later threw the phone onto the Metro tracks when approached by police.The Superior Court of the District of Columbia convicted Holman of the charges. Holman appealed, arguing that his convictions for simple assault and AWIR should merge with his robbery conviction under the Double Jeopardy Clause. He also contended that there was insufficient evidence to support his robbery conviction.The District of Columbia Court of Appeals reviewed the case. The court agreed with Holman that his convictions for simple assault and AWIR should merge with his robbery conviction, as robbery requires proof of assault, and thus, the lesser offenses are included within the greater offense of robbery. The court also found that there was sufficient evidence to support Holman’s robbery conviction, as a reasonable jury could infer that Holman intended to permanently deprive Dotson of her phone.The Court of Appeals reversed Holman’s convictions for simple assault and AWIR, affirmed his robbery conviction, and remanded the case for entry of a new judgment and commitment order reflecting only the robbery conviction. The court noted that resentencing was unnecessary as the trial court had imposed concurrent sentences. View "Holman v. United States" on Justia Law

Paul Porter applied twice to register a firearm, but the District of Columbia Metropolitan Police Department (MPD) denied his applications, citing a previous weapons offense conviction in Maryland. The Maryland records were expunged in 2020, so the full details of the case are not available. However, it is known that Porter pleaded guilty in 2009 to transporting a handgun on a highway, was initially sentenced to three years of incarceration (suspended for probation), and later had his sentence reconsidered to probation before judgment in 2015.Porter sought review of MPD's denial from the Office of Administrative Hearings (OAH). The Administrative Law Judge (ALJ) at OAH overturned MPD's decision, reasoning that under Maryland law, a discharged sentence of probation before judgment is not considered a conviction and that failing to recognize this would deny Maryland law full faith and credit.The District of Columbia Court of Appeals reviewed the case. The court held that the Full Faith and Credit Clause does not compel the District to adopt Maryland's interpretation of "conviction" for firearm registration purposes. The court concluded that under District law, a sentence of probation before judgment constitutes a conviction for the purposes of firearm registration. The court emphasized that the legislative intent of the Firearms Control Regulations Act of 1975 was to restrict firearm possession to individuals without disqualifying offenses, and allowing those with probation before judgment to register firearms would undermine this purpose.The court reversed OAH's order and upheld MPD's denial of Porter's application for a firearm registration certificate, holding that Porter "has been convicted" of a disqualifying offense under D.C. Code § 7-2502.03(a)(2), and that subsequent discharge of probation and expungement do not alter this conclusion. View "District of Columbia Metropolitan Police Department v. Porter" on Justia Law