Justia District of Columbia Court of Appeals Opinion Summaries

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