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United States v. James Milton Stephens, United States of America v. Tony Anthony McCray

Citations: 23 F.3d 553; 306 U.S. App. D.C. 245; 1994 U.S. App. LEXIS 12389; 1994 WL 220335Docket: 92-3050, 92-3073

Court: Court of Appeals for the D.C. Circuit; May 27, 1994; Federal Appellate Court

Narrative Opinion Summary

The case involves the appeal of two individuals, Stephens and McCray, against their convictions for drug offenses under federal law. The United States Court of Appeals for the District of Columbia Circuit reviewed the convictions related to drug activities occurring within 1,000 feet of a school. Stephens's conviction for distribution of cocaine base was upheld, as the court found sufficient evidence to support the charge, including eyewitness testimony and the circumstances of his arrest. Conversely, McCray's conviction for possession with intent to distribute was vacated due to insufficient evidence demonstrating intent. The court found that the evidence, which included cash found on McCray and the context of his arrest, was inadequate to prove beyond a reasonable doubt his intent to distribute, as required under 21 U.S.C. § 860(a). Instead, the court remanded the case for sentencing on the lesser charge of simple possession under 21 U.S.C. § 844(a). The court also addressed procedural matters, affirming the denial of the motion to suppress evidence against both defendants. As a result, while Stephens's conviction was affirmed, McCray's sentence was adjusted to reflect the lesser charge, and he was to be resentenced accordingly.

Legal Issues Addressed

Drug Distribution within Proximity to a School under 21 U.S.C. § 860(a)

Application: Stephens's conviction for distribution of cocaine base within 1,000 feet of a school was affirmed, as the court found sufficient evidence to support his conviction.

Reasoning: The United States Court of Appeals for the District of Columbia Circuit affirms Stephens's conviction for distribution of cocaine base within 1,000 feet of a school, finding no merit in his claims of error.

Insufficient Evidence for Intent to Distribute under 21 U.S.C. § 860(a)

Application: McCray's conviction was vacated due to insufficient evidence of intent to distribute, as the court found no rational jury could find intent based on the evidence presented.

Reasoning: The evidence was inadequate to prove McCray's intent to distribute crack cocaine, which is essential for his conviction under 21 U.S.C. Sec. 860(a).

Probable Cause and Motion to Suppress

Application: The court upheld the denial of the motion to suppress, affirming the determination of probable cause based on the evidence presented during the police intervention.

Reasoning: The court found no merit in the appellants' challenges to the District Court's denial of their motion to suppress, affirming the determination of probable cause based on the evidence presented.

Simple Possession under 21 U.S.C. § 844(a)

Application: McCray's case was remanded for sentencing on the lesser charge of simple possession after vacating his conviction for possession with intent to distribute.

Reasoning: The court vacated McCray's conviction under 21 U.S.C. § 860(a) and remanded the case for a judgment of conviction under the first sentence of § 844(a) for resentencing.