United States v. Soto-Zuniga, No. 14-50529 (9th Cir. 2016)
Annotate this CaseDefendant appealed his conviction for possession with intent to distribute methamphetamine in violation of 21 U.S.C. 841(a)(1). At both his first trial and his subsequent re-trial, defendant testified that before being stopped at a checkpoint, he had given a ride to three teenagers he did not know as a favor to his cousin’s husband, Christian Rios Campos. Rios was a known drug smuggler who recruited juveniles, and defendant's primary defense was that the teenagers had planted the drugs in the car without his knowledge. On appeal, defendant argued, inter alia, that the district court abused its discretion by denying his pretrial motion for discovery relating to the constitutionality of the San Clemente checkpoint, and the district court abused its discretion by denying his motion for discovery on Rios’s drug smuggling operation. The court agreed with defendant that the district court abused its discretion in denying discovery that could have revealed an unconstitutional seizure and led to the suppression of the evidence that illicit drugs were found in defendant's car. In this case, whether the primary purpose of the checkpoint has evolved from controlling immigration to detecting“ordinary criminal wrongdoing,” is a question that is subject to discovery under Federal Rule of Criminal Procedure 16(a)(1)(E). Therefore, the court reversed and remanded for further proceedings on this issue. The court also reversed the district court’s denial of discovery of the government’s investigation into Rios’s drug smuggling operation. After reviewing documents submitted by the government, the court disagreed both with the district court’s characterization of the documents and with its application of the law. Therefore, the court reversed the denial of defendant's discovery motion, vacated the conviction, and remanded with instructions to grant the motion. Finally, the court affirmed the district court's denial of defendant's motion to suppress; rejected defendant's challenge to a jury instruction; and concluded that defendant's knowledge of the type and quantity of the drugs found in his car is not an element under 21 U.S.C. 841.
Court Description: Criminal Law. The panel vacated a jury conviction for possession with intent to distribute methamphetamine, reversed discovery rulings, and remanded with instructions. The panel held that the district court abused its discretion by denying the defendant’s pretrial motion for discovery relating to the constitutionality of a Border Patrol checkpoint at which the defendant was detained and his car searched. The panel concluded that discovery of the checkpoint search and arrest statistics was pertinent to the issue whether the checkpoint was invalid under the Fourth Amendment because its primary purpose was to advance the general interest in crime control, rather than to control immigration. The panel held that this issue of the constitutionality of a search or seizure was subject to discovery under Federal Rule of Criminal Procedure 16(a)(1)(E). The panel reversed the district court’s denial of the discovery motion relating to the checkpoint’s arrest statistics and remanded for the district court to assess the constitutionality of the checkpoint in further proceedings. The panel held that the district court abused its discretion by denying the defendant’s motion for discovery on the government’s investigation into a drug smuggling operation. After reviewing sealed documents submitted by the government, the panel concluded that the documents were UNITED STATES V. SOTO-ZUNIGA 3 discoverable because they were material to preparing the defense under Rule 16(a)(1)(E). The panel reversed the denial of the discovery motion, vacated the conviction, and remanded with instructions to grant the motion. The panel also instructed the district court to consider the government’s request for a window of time before production to determine whether to continue to pursue the case, and to consider the government’s request for protective measures that would maintain the security of the information in the documents while allowing the defense to adequately prepare a defense. The panel affirmed the denial of a suppression motion insofar as it was based on a claimed lack of probable cause for the search of the defendant’s car. The panel held that the district court did not err in instructing the jury on reasonable doubt. It also held that knowledge of drug type and quantity is not an element of possession with intent to distribute in violation of 21 U.S.C. § 841.
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