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United States v. Watson, No. 11-4371

Decided: January 2, 2013

The Fourth Circuit Court of Appeals reversed the district court’s decision to deny a motion to suppress defendant’s statement.  The Court held that defendant’s three-hour detention violated his Fourth Amendment Rights, vacated the judgment, and remanded the case.

Prentiss Watson was convicted of possession of a firearm by a felon and possession of ammunition by a felon, in violation of 18 U.S.C. § 922(g).  The convictions stemmed from a statement he made while detained by Baltimore police officers.  The officers were observing drug activity in a building in which Watson both worked and lived.  After arresting a target for drug related activities and not finding a firearm, the officers decided to search the building.  At the time, Watson and his employer were working at the convenience store on the first floor of the building. According to procedures, the officers checked the building for armed suspects and detained all individuals in the building, and put them in a central location.  While waiting for a search warrant, the officers detained Watson for three-hours.  The officers informed Watson of his Miranda rights before detaining him.  The officers had no information linking Watson to any crime.  Watson was never told that he was free to leave, and during the three-hour detention, he was asked no questions.  After securing the search warrant, an officer found a shotgun in the back room of the second floor.  After informing him of his Miranda rights, the officer asked Watson about the gun.  He replied that he lived in the front room of the second floor and did not know about the shotgun.  The officer returned to the front room and found a Ziploc bag with a revolver and various ammunition.  When asked about it, Watson replied, “[T]hat old thing, it doesn’t even work.”  At trial, Watson filed a motion to suppress his statement on the grounds that he was subjected to an unlawful detention without probable cause, and that his statement was the product of an illegal arrest.  The district court denied the motion.  Watson was convicted and sentenced to consecutive terms of 31 months.  This appeal followed.

The Fourth Circuit first determined that Watson was seized for purposes of the Fourth Amendment because a reasonable person would not have felt free to leave.  Because the seizure was unsupported by probable cause, the Court employed a balancing test of the legitimate government (public) interests and personal privacy interests to determine reasonableness.  The Court held that the intrusion into Watson’s privacy interests outweighed public concerns, mainly protecting officer safety and preventing the destruction of evidence.  Precedent relied on by the government which allowed such action were distinguishable because here, unlike other cases, the officers did not already have a warrant and could not tie Watson to any criminal activity to justify detention for safety reasons.  For these reasons, Watson’s detention was an illegal custodial arrest.  Additionally, the Court stated that there was no break in the casual chain between the illegal seizure and the statement made by Watson.  Despite the Miranda warnings given and lack of flagrant police misconduct, the Court held that no intervening circumstances occurred which sufficiently attenuate the illegal arrest from Watson’s statement.  Finally, the erroneous admission of Watson’s statement was not harmless error because the evidence presented by the government to prove Watson knowingly owned a firearm included Watson’s statement and the Court was unable to conclude that a reasonable fact-finder would have found Watson guilty beyond a reasonable doubt without the statement.

Full Opinion

–Jonathan Riddle