USA v. Pierson, No. 21-3248 (7th Cir. 2024)
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This case involves the appeal of a judgment convicting Byron Pierson of unlawful possession of a firearm by a felon. Pierson contested the decision, arguing that the district court erred by not holding a hearing to determine if he had knowingly and voluntarily waived certain rights when he entered into a proffer agreement with the government. Furthermore, he argued that the court erred by allowing a witness to testify about the investigation that led to his arrest. The United States Court of Appeals For the Seventh Circuit affirmed the district court's decisions.
The case began when an Indianapolis Police Officer responded to a 911 call from a woman who reported that Pierson threatened to "come back and shoot the house up." After learning about Pierson's criminal record and obtaining a description of his car, the officer decided to return to the woman's home later that evening. Upon returning, the officer saw the car described by the woman and initiated a traffic stop. Pierson was in the back seat of the car. When asked to step out of the car, Pierson hesitated and then fled on foot when an attempt was made to handcuff him. During the ensuing chase, officers saw a firearm under Pierson's body, which was later retrieved and used as evidence against him.
Prior to his trial, Pierson had entered into plea negotiations with the government, signing a Proffer Letter that waived certain rights. After admitting possession of the firearm in two proffer sessions, Pierson withdrew his plea and decided to go to trial. Pierson moved to exclude statements he made during these plea negotiations, arguing that he had not knowingly and voluntarily waived his rights.
The Court of Appeals found that Pierson failed to provide an evidentiary basis for his assertion that he had not knowingly and voluntarily entered into the proffer agreement. Given the lack of evidence to the contrary, the court did not find it necessary to hold an evidentiary hearing, and the proffer waiver was deemed valid. The court also noted that the government never sought to introduce any of Pierson's proffer statements at trial, meaning any potential error in refusing to hold a hearing was harmless.
Additionally, Pierson contended that the district court erred in allowing the government to present evidence about the investigation that led to his arrest. The court found that Pierson had opened the door to this testimony in his opening statement by referencing a complaint made by his ex-girlfriend. The district court did not abuse its discretion in allowing this testimony, and immediately gave a limiting instruction to the jury on the proper use of this evidence.
Given the strong evidence of Pierson's guilt, the Court of Appeals affirmed the district court's decisions.
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