United States v. Stoddard, No. 15-3060 (D.C. Cir. 2018)Annotate this Case
Defendants Stoddard and Woodruff were convicted of conspiracy to distribute and possess with intent to distribute heroin. Defendant Cobble, who was tried together with Stoddard and Woodruff, was acquitted of the same charges but convicted of conspiracy to launder money. The DC Circuit affirmed the denial of defendants' motions to suppress evidence obtained as a result of wiretaps because the district court did not abuse its discretion in finding that the Government had met the "necessity" requirement; affirmed the denial of Stoddard's and Woodruff's motions for acquittal; affirmed the denial of Woodruff's motion in limine to exclude evidence of a prior conviction if Woodruff had testified in his own defense; found no plain error in the district court's jury instructions on the money-laundering charge; (5) reversed the denial of Cobble's motion for acquittal because the evidence was insufficient to sustain his conviction; vacated the sentences of Stoddard and Woodruff, remanded for resentencing, and held that, in order for a defendant to be sentenced based on a mandatory minimum triggered by a certain quantity of drugs, a jury must find the drug quantity attributable to the defendant on an individualized basis, not just the drug quantity attributable to the conspiracy as a whole; and reserved judgment on whether the district court properly applied the career-offender enhancement before sentencing Woodruff.