Tawanda Sheffield, Steven D. Lewis, and Allen Butler v. United States

Summary

The District of Columbia Court of Appeals reviewed consolidated appeals from the convictions of Tawanda Sheffield, Steven D. Lewis, and Allen Butler. The appellants raised issues involving the Fourth Amendment, Miranda rights, confrontation, Brady disclosures, evidentiary rulings, jury proceedings, and sufficiency of the evidence. The court affirmed in part and remanded for vacatur of one of Sheffield’s obstruction of justice convictions and adjustment of her sentence as necessary.

Holdings

1. The seizure of Butler's clothing did not violate the Fourth Amendment because, assuming the Amendment applied, the clothing was lawfully seized under the plain-view exception.
2. The transfer of the lawfully seized clothing between police departments and the subsequent extraction and testing of blood from it did not violate the Fourth Amendment.
3. The trial court properly denied suppression of Butler's statements because Butler initiated further communication with police and voluntarily and intelligently waived his Miranda rights.
4. Butler was not entitled to reversal based on the medical examiner's testimony because he failed to object, further developed the testimony on cross-examination, and could not establish plain error.
5. The trial court did not abuse its discretion in denying mistrial motions based on delayed disclosure of the Gangsta identification and the midtrial discovery that Gangsta was Gary Young.
6. Admission of Young's rebuttal testimony and the ski-mask demonstration was not reversible or plain error.
7. The evidence was sufficient to support Lewis's convictions for second-degree murder while armed, assault with intent to kill while armed, and related weapons offenses.
8. The evidence was sufficient to support Sheffield's perjury conviction and the obstruction conviction based on her grand-jury testimony, but insufficient to support the separate obstruction conviction based on her police statement because no official proceeding then existed.
9. Sheffield's perjury and obstruction convictions did not merge under Blockburger, and joinder with Butler and Lewis was proper.

Questions Presented

1. Whether the warrantless seizure of Butler's clothing from a public hospital violated the Fourth Amendment.
2. Whether the transfer and forensic DNA testing of Butler's clothing violated the Fourth Amendment.
3. Whether Butler's statements to police were obtained in violation of Miranda or Edwards.
4. Whether expert testimony concerning the autopsy violated Butler's confrontation rights.
5. Whether delayed disclosure of eyewitness information and midtrial discovery of the identity of a person nicknamed Gangsta required a mistrial under Brady.
6. Whether the government's rebuttal testimony and ski-mask demonstration constituted reversible or plain error.
7. Whether sufficient evidence supported Lewis's convictions for murder, assault, and related weapons offenses.
8. Whether sufficient evidence supported Sheffield's perjury and obstruction-of-justice convictions.
9. Whether Sheffield's obstruction and perjury convictions merged under Blockburger.
10. Whether joinder of Sheffield's case with the cases against Butler and Lewis was improper or prejudicial.

Disposition

reversed_and_remanded