United States v. Baez, No. 19-2823 (8th Cir. 2020)
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Police stopped Anguiano for expired license plates. The car contained a fake DEA badge and cash. At the hotel where Anguiano was staying, Baez’s wife, Gavino, admitted the officers. Baez was sitting next to Chevrolet keys and a methamphetamine pipe. Gavino consented to a search. In a backpack, officers found a Chevrolet Equinox owner’s manual. A locked armoire appeared to be under video surveillance. A canine unit alerted at the armoire and at an Equinox that responded to the Chevrolet keys. With a warrant, officers searched the hotel suite and the Equinox. The armoire held methamphetamine and a gun. The Equinox contained methamphetamine, another firearm, and a safe with ammunition and receipts in Baez’s name. The other conspirators pled guilty.
The court denied Baez’s motions to suppress the evidence and his incriminating statements. Baez, claiming that he was infiltrating the conspiracy to assist law enforcement, sought to introduce evidence regarding his mental health and a potential informant with whom he was acquainted. Baez moved to compel the government to disclose information about the informant. The court excluded the evidence, partially granted his Brady motion, and declined to instruct the jury that it would “negate[] the specific intent required” if Baez intended to “assist ongoing federal investigations.” The court departed from the guidelines range of 360 months’ to life imprisonment, sentencing Baez to 168 months’ imprisonment.
The Eighth Circuit affirmed, upholding the denial of his suppression motions, the failure to instruct the jury on an “innocent-intent” defense, the exclusion of the evidence related to that defense, the partial denial of his Brady motion, and the reasonableness of his sentence.
Court Description: [Gruender, Author, with Chief Judge Smith and Loken, Circuit Judges] Criminal Case - Conviction and Sentence. After officers were granted consent to enter and search hotel suite, officers proceeded through open door to back room. Dogs alerted to locked armoire and car flashed its lights when officers pressed car keys. Drugs found in back room and under sink. Baez was arrested. After a search warrant was obtained, drugs and firearms were found in armoire and in safe in the car. Coconspirator's motion to suppress evidence was denied. Baez's motion to suppress evidence found in back room, in safe in car, and incriminating statements were denied. Following jury conviction and 168-month sentence, Baez appeals. For complete discussion of the independent source and inevitable-discovery doctrines; evidence found under the sink, in the armoire, and in the safe in the Equinox was admissible. As for Baez's incriminating statements, Maryland v. Pringle holding is hereby extended to hotel suites and police had probable cause to believe everyone in hotel suite was involved in drug trafficking, Baez's arrest was lawful, and the district court did not err in denying motion to suppress his incriminating statements made while in custody. Baez's innocent-intent jury instruction misstated the law and his intent to assist law enforcement does not negate his mens rea. The district court did not abuse its discretion in excluding evidence relating to his innocent-intent theory, as evidence was irrelevant and was otherwise confusing. District court did not abuse its discretion in denying motion to compel disclosure of Brady material after in camera review, as it was not exculpatory and did not tend to impeach government witness. Sentence that was varied downward by fifty percent was not unreasonable. Judge Loken concurs in judgment and joins in opinion except section 11.A.2.
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