United States v. Rodriguez, No. 11-3321 (8th Cir. 2013)
Annotate this CaseDefendant appealed his conviction of charges related to methamphetamine and firearms. The court held that the district court did not err in denying his motion to suppress the statements he made after he was asked to exit his vehicle, the handgun and a methamphetamine pipe located in the vehicle, and firearms seized during the search of his home. Further, the court affirmed the jury's conviction and the district court's denial of defendant's renewed motion for acquittal; the court need not decide whether the district court erred in applying a two-level enhancement for possessing a stolen firearm under U.S.S.G. 2K2.1(b)(4) because the district court used an offense level of 37 based on the drug offenses calculated in defendant's sentence; and the court rejected defendant's contentions related to his criminal history. Accordingly, the court affirmed the conviction and sentence.
Court Description: Criminal case - Criminal law and sentencing. Asking defendant to get out of his car was not the functional equivalent of an arrest, and the statements he subsequently made to the officer were admissible; search of his car was supported by probable cause after defendant told the officer he had a handgun and a meth pipe in the car; the police affidavit submitted in support an application for a warrant to search defendant's home established probable cause; guns found in plain view were properly seized even if they were not listed in the warrant; evidence was sufficient to show defendant possessed a firearm while being a convicted felon and a user of controlled substances; drug quantities were properly calculated; any error in imposing a two-level enhancement under Guidelines Sec. 2K2.1(b)(4) for possession of a stolen firearm was harmless as defendant's offense level was determined under grouping rules and the error did not impact his highest offense level under those rules; no error in imposing criminal history points for certain prior convictions.
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