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United States v. Joe Michael Robinson, Also Known as Ice Mike

Citation: 119 F.3d 663Docket: 17-1322

Court: Court of Appeals for the Eighth Circuit; August 15, 1997; Federal Appellate Court

Narrative Opinion Summary

In this appeal, the appellant challenged the denial of his motion to suppress evidence obtained during a vehicle stop and his subsequent sentence under the Career Offender provision of the federal sentencing guidelines. The initial incident involved federal agents surveilling a residence tied to drug activity, leading to the appellant's stop based on suspected drug possession. The court found that the officers had reasonable suspicion for the stop, supported by the appellant's known history and behavior during the incident. As a result, the evidence and confession were deemed admissible. Procedurally, the appellant entered a conditional guilty plea after his motion to suppress was denied, preserving his right to appeal the ruling. During sentencing, the court applied an enhanced penalty due to the appellant's prior convictions, aligning with the Career Offender guidelines, despite the appellant's contention for a lower sentence. His arguments against the application of the statutory maximum sentence and Amendment 506 were dismissed, as the court adhered to established precedents. Ultimately, the Court of Appeals affirmed the district court's decisions regarding both the suppression and sentencing issues, resulting in a final sentence of 197 months after accounting for cooperation and acceptance of responsibility.

Legal Issues Addressed

Application of Terry v. Ohio

Application: The officer's actions during the stop, including the pat-down search, were justified under the Terry doctrine as the officer had specific, articulable facts indicating possible criminal activity.

Reasoning: A police officer can conduct a brief, warrantless stop if there is a reasonable belief of criminal activity, as established in Terry v. Ohio.

Career Offender Sentencing Enhancement

Application: The appellant's sentence was enhanced under the Career Offender section due to prior felony drug convictions, which the court deemed appropriate and in line with statutory requirements.

Reasoning: The government later notified him of enhanced penalties due to a prior felony drug conviction, classifying him as a career offender under the Federal Sentencing Guidelines.

Invalidity of Sentencing Amendment

Application: Appellant's argument regarding Amendment 506 was rejected based on prior case law, which found the amendment conflicting with statutory requirements.

Reasoning: An amendment conflicting with this statutory requirement is deemed invalid.

Reasonable Suspicion for Traffic Stops

Application: The court found that the officers had reasonable suspicion to stop the appellant's vehicle based on his known history as a drug dealer and the observed drug activity at the residence.

Reasoning: The court found reasonable suspicion justified the vehicle stop and pat-down, and determined the confession was not tainted by illegality.