Justia District of Columbia Court of Appeals Opinion Summaries

Corey Nelson-White was barred from Rhode Island Row, a mixed-use development in Northeast D.C., which includes two buildings at 2300 and 2350 Washington Place NE. The barring notice directed him to stay off the property and grounds of Rhode Island Row. Officers explained the barring notice to Nelson-White, but did not provide him with a copy. Six days later, Nelson-White was found inside a parking garage attached to one of the Rhode Island Row buildings and was arrested for unlawful entry.The Superior Court of the District of Columbia convicted Nelson-White of unlawful entry, finding that he knew or should have known he was barred from the premises, including the parking garage. The trial court based its decision on the barring notice and the officers' instructions, despite Nelson-White's argument that the garage was not clearly marked as part of Rhode Island Row.The District of Columbia Court of Appeals reviewed the case and found the evidence insufficient to sustain Nelson-White's conviction. The court noted that there was no clear indication that the parking garage was part of the barred premises. The court highlighted the lack of signage or other markers that would inform a reasonable person that the garage was part of Rhode Island Row or 2350 Washington Place. The court concluded that a rational fact-finder could not determine beyond a reasonable doubt that Nelson-White knew or should have known the garage was included in the barring notice.The District of Columbia Court of Appeals reversed Nelson-White's conviction for unlawful entry, holding that the evidence did not support the conclusion that he was aware or should have been aware that the parking garage was part of the premises he was barred from entering. View "Nelson-White v. United States" on Justia Law

G.W. was convicted of simple assault in 2019 after allegedly grabbing the jacket of a Metropolitan Transit Police Department officer outside the Anacostia Metro Station. G.W. filed a notice of appeal, and the case was remanded to allow the trial court to set aside his conviction under the Youth Rehabilitation Act (YRA). Following the trial court's set-aside order and issuance of a new judgment and commitment order, G.W. filed a new notice of appeal, challenging his conviction.The Superior Court of the District of Columbia initially convicted G.W. of simple assault. G.W. timely filed a notice of appeal, and the case was stayed pending the outcome of the en banc decision in Perez Hernandez v. United States, which addressed the elements of an offensive touching assault. After the decision in Perez Hernandez, the stay was lifted, and G.W. sought an indicative ruling for a YRA set-aside. The trial court issued an indicative set-aside order, and the case was remanded. The trial court then issued a set-aside order and an amended judgment and commitment order, which G.W. appealed.The District of Columbia Court of Appeals reviewed the case and concluded that G.W.'s appeal was properly before the court. The court determined that the trial court had not applied the correct elements of an offensive touching assault as defined in Perez Hernandez. Specifically, the trial court did not consider whether G.W.'s actions would offend a person's reasonable sense of personal dignity and whether G.W. acted with the purpose of causing offense or knowing that his actions would cause offense. The court vacated the judgment and remanded the case for the trial court to make the necessary findings regarding G.W.'s mens rea and the nature of the touch. The court did not reach G.W.'s Rule 16 claim due to the decision to remand. View "G.W. v. United States" on Justia Law

The appellant was convicted of two counts of simple assault and one count of attempted possession of a prohibited weapon. The incidents involved an altercation with his girlfriend, Ms. Williams, and her daughter, M.W. Ms. Williams testified that the appellant slapped her at a Metro station, and later, after an argument, he kicked in her apartment door, punched her, and hit M.W. with a belt. Ms. Williams also claimed the appellant had a gun, which he used to hit her. The police arrived shortly after the incident, and body-worn camera footage captured Ms. Williams's statements and visible injuries.The Superior Court of the District of Columbia found the appellant guilty of both counts of simple assault and attempted possession of a prohibited weapon. The court credited Ms. Williams's testimony and found the video evidence, particularly Exhibit 7, significant in showing the appellant holding his belt while running out of the building. The court did not credit the appellant's testimony and found the injuries on Ms. Williams consistent with being hit rather than a fall.The District of Columbia Court of Appeals reviewed the case. The court accepted the United States' concession that the evidence was insufficient to support the conviction for attempted possession of a prohibited weapon and reversed that conviction. The court found the evidence sufficient to support the assault convictions but held that the trial court erred in admitting Exhibit 7, which was harmful error regarding the conviction for assaulting M.W. Consequently, the court vacated that conviction and remanded the case for further proceedings. The court affirmed the conviction for assaulting Ms. Williams, finding any error in admitting the video exhibits harmless concerning that conviction. View "Ransom v. United States" on Justia Law

In 2002, the appellant was convicted of armed robbery and assault with a dangerous weapon. He later filed two motions for post-conviction relief under D.C. Code § 23-110. The first motion, filed in 2017, claimed ineffective assistance of trial counsel and alleged that he was beaten by U.S. Marshals during his trial, rendering him unable to participate meaningfully in his defense. He attached an affidavit and medical records to support his claims. The second motion, filed pro se, argued ineffective assistance of post-conviction counsel during a 2016 sentence reduction hearing.The Superior Court of the District of Columbia denied the first § 23-110 motion after an evidentiary hearing. The court found that the appellant's absence from the hearing meant his affidavit was inadmissible hearsay and that the medical records did not sufficiently demonstrate that he was unable to participate in his trial. The court concluded there was no evidence, aside from the inadmissible affidavit, to support the claim that the appellant was too emotionally or physically impaired to assist in his defense.The appellant's second § 23-110 motion was also denied by the Superior Court. The court found that the appellant had not demonstrated prejudice from his post-conviction counsel's performance during the Rule 35 sentence reduction hearing. The appellant appealed both denials.The District of Columbia Court of Appeals reviewed the case. It affirmed the denial of the first § 23-110 motion, agreeing with the lower court that the appellant's affidavit was inadmissible and that the medical records did not prove his inability to participate in his trial. The court dismissed the appeal of the second § 23-110 motion as moot because the appellant had already completed his term of imprisonment, and his term of supervised release was statutorily unalterable. View "Thompson v. United States" on Justia Law

In this case, four individuals, alleged members of the criminal street gang "G-Rod," were involved in three separate shootings in 2010, resulting in two deaths and two injuries. The defendants, Lester Williams, Robert Givens, Marcellus Jackson, and Keir Johnson, were convicted of various crimes related to these incidents after a four-month jury trial.The Superior Court of the District of Columbia presided over the trial. The court admitted a rap video as evidence, which the defendants argued was inadmissible. The court also allowed lay interpretation of coded conversations and addressed issues related to jury selection, including the government's selective investigation of potential jurors and the use of peremptory challenges. The court denied motions to suppress certain evidence and ruled on the admissibility of cell-site data.The District of Columbia Court of Appeals reviewed the case. The court held that the convictions of Jackson, Johnson, and Williams should be remanded for a Motorola hearing regarding the admissibility of cell-site evidence. The court also concluded that the convictions under D.C. Code § 22-951(b) related to misdemeanor conspiracy could not stand and that certain duplicative convictions must merge. The court vacated Jackson's conviction for second-degree murder due to insufficient evidence and the related street gang conviction. The court found no reversible errors in the other aspects of the trial and affirmed the remaining convictions.The court's main holdings included the need for a remand to apply the Motorola standard to the cell-site evidence, the vacating of certain convictions due to insufficient evidence, and the merging of duplicative convictions. The court also addressed issues related to jury selection and the admissibility of evidence, ultimately affirming most of the convictions while remanding for further proceedings on specific issues. View "Williams, et al. v. United States" on Justia Law

On the evening of September 10, 2018, Metropolitan Police Department officers received a ShotSpotter alert indicating a possible gunshot near their location. Shortly after, they encountered Maurice Mitchell riding a bicycle away from the general area of the alert. The officers testified that Mitchell flinched and increased his speed upon noticing their patrol car. They followed him, activated their emergency lights, and stopped him. Upon approaching Mitchell, they observed a firearm protruding from an open bag on his bicycle. Mitchell was subsequently convicted of multiple firearm-related offenses following a stipulated trial.The Superior Court of the District of Columbia denied Mitchell's motion to suppress the firearm, ruling that the officers had reasonable suspicion to stop him based on his proximity to the ShotSpotter alert, his evasive behavior, and the lateness of the hour. Mitchell was convicted and sentenced to eighteen months of incarceration, suspended as to all but twelve months, followed by supervised release and probation. He appealed the denial of his motion to suppress, arguing that the stop was unlawful due to a lack of particularized and articulable suspicion.The District of Columbia Court of Appeals reviewed the case and concluded that the officers lacked reasonable, articulable suspicion to stop Mitchell. The court found that the factors cited by the trial court, including Mitchell's proximity to the ShotSpotter alert, his attire, and his behavior, were insufficient to justify the stop. The court emphasized that the totality of the circumstances did not provide a particularized and objective basis for suspecting Mitchell of criminal activity. Consequently, the court reversed the trial court's denial of the motion to suppress, vacated Mitchell's convictions, and remanded the case for further proceedings consistent with its opinion. View "Mitchell v. United States" on Justia Law