United States v. Brooks, No. 19-2283 (6th Cir. 2021)
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Police officers pulled over the vehicle in which Brooks was riding for a seatbelt violation. The officers approached, smelled marijuana, and saw Brooks making a “stuffing motion” under his seat. The police found a gun partially hidden there. After a jury convicted Brooks of being a felon in possession of a firearm, the lone African-American juror emailed the court that the other jurors had pressured her into a guilty verdict.
On appeal, Brooks claimed that the stop and search of the vehicle violated the Fourth Amendment, that the prosecution presented insufficient evidence that he “possessed” a gun, and that he is entitled to an evidentiary hearing under Peña-Rodriguez v. Colorado, to investigate the racial biases of the other jurors.
The Sixth Circuit affirmed Brooks’s conviction and 66-month sentence. The number of officers who conducted the traffic stop did not affect whether it was “reasonable” under the Fourth Amendment. The felon-in-possession statute does not require a defendant to control a gun for any significant period of time. Peña-Rodriguez does not permit an evidentiary hearing to impeach a jury verdict even when no jurors made race-based statements.
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