United States v. Caldwell, No. 19-4019 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed defendant's convictions for charges related to bank robbery and firearm possession, rejecting his numerous claims of error. The court concluded that the automobile exception justified both searches of the vehicle and thus there was no error in denying defendant's motion to suppress evidence; there was no abuse of discretion in denying defendant's motion to disqualify a witness's counsel and to exclude witness testimony where the district court satisfied itself that no actual conflict jeopardized the integrity of the proceedings; even if the district court committed evidentiary errors, the errors were harmless; defendant waived his claim of work-product privilege regarding the private investigator's notes; defendant failed to make a showing of materiality under either Brady v. Maryland, 373 U.S. 83 (1963), or the less onerous standard for in camera review; viewing the evidence in the light most favorable to the government, ample evidence supported the verdict; and defendant's two arguments raised for the first time on appeal under Federal Rule of Criminal Procedure 52(b) failed because either defendant's substantial rights were not affected or binding precedent foreclosed his arguments.