Date: 11-06-2024

Case Style:

United States of America v. Deandre Jackson and Quintel Martin

Case Number: 2:21-Cr-54

Judge: Juan R. Sanchez

Court: United States District Court for the Eastern District of Pennsylvania (Philadelphia County)

Plaintiff's Attorney: United States District Attorney's Office in Philadelphia

Defendant's Attorney:

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Description:

Philadelphia, Pennsylvania criminal defense lawyers represented the Defendants charged with:

a five-count Indictment charging Jackson, Martins, and Winfield with: (1) conspiracy to interfere with interstate commerce by robbery, in violation of 18 U.S.C. §1951(a)(Count 1); (2) interference with interstate commerce by robbery and aiding and abetting, in violation of 18 U.S.C. §§ 1951(a) and 2 (Counts 2 and 4); and (3) using, carrying, and brandishing a firearm during and in relation to a crime of violence and aiding and abetting, in violation of 18 U.S.C. §§ 924(c)(1)(A)(ii) and 2 (Counts 3 and 5). Jackson and Martins both filed pre-trial motions to suppress the physical evidence that the officers recovered from their vehicle.In his motion, Jackson argued that: (1) the officers’ investigativestop amounted to an arrest that was not supportedby probable cause; (2) the stop was unreasonably prolonged beyond the time necessary for a valid traffic stop; and (3) the search of the vehicle’s trunk was not supportedby probable cause. Similarly, Martins argued that he was arrested without probable cause and that the officers did not have probable cause to search the trunk of the vehicle.

Outcome:
7Governmentcontendedthat Jackson lacked standing to raise a Fourth Amendment challenge to the officers’ search of the vehicle because he was merely a passenger and did not have a legitimateexpectation of privacy inthe interior of the vehicle. The District Court helda suppression hearing on April 1, 2022 and denied both motions to suppress. The Court determined that the traffic stop and the search werelawful, explaining that “[Officer McCauley] offered substantial justification for his suspicion that the Defendants may be armed, and given the circumstances of the stop, he took certain precautions to ensure his safety.” United States v. Martins, No. 21-54, 2022 WL 2805328, at *5 (E.D. Pa. July 15, 2022).In so concluding, the Court credited Officer McCauley’s testimony that he observed multiple “traffic code violations,” including the broken taillight and expired registration; that the area where he stopped the vehicle was “dark, secluded” and was known to him as one where “criminal activity . . . sometimes occurred”; and that the suspects outnumbered him. Id. at 4. The Court further determined that the officers had probable cause to enter and search the vehicle because Jackson admitted that there was an illegal firearm in the car and because the officers credibly testified that they smelled marijuana once they entered the vehicle. The Court did not discuss the Government’s argument that Jackson lacked standing to raise his Fourth Amendment claim or its contention that the evidence would have inevitably been discovered.On November 29, 2022, Jackson pleadedguilty to Counts 1, 2, and 4 of the Indictment, preserving his right to challenge the Court’s denial of his motion to suppress.The District Court sentenced him to 84 months in prison and a three-year term of supervised release. A month later, Martins pleadedguilty to all five counts of the Indictment, similarly
8preserving his right to challenge the Court’s denial of his motion to suppress.The Court sentenced Martins to 186 months in prison and a five-year term of supervised release.

Affirmed

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