Precedents Cited

The judgment extensively references several landmark cases that have shaped the current legal landscape concerning surveillance, search and seizure, and criminal statutes:

• Carpenter v. United States (138 S. Ct. 2206, 2018): Established that accessing historical CSLI constitutes a search under the Fourth Amendment, thereby requiring a warrant.
• Rehaif v. United States (139 S. Ct. 2191, 2019): Determined that the felon-in-possession statute (§ 922(g)) necessitates proof that a defendant knew of their felon status.
• UNITED STATES v. KNOTTS (460 U.S. 276, 1983): Clarified that tracking a suspect's movements using a beeper without physical intrusion does not constitute a search under the Fourth Amendment.
• United States v. Jones (565 U.S. 400, 2012): Held that attaching a GPS device to a vehicle constitutes a search under the Fourth Amendment.
• United States v. Anglin (846 F.3d 954, 2017): Affirmed that Hobbs Act robbery qualifies as a crime of violence under the elements clause of 18 U.S.C. § 924(c).

Additionally, the court cited doctrines such as the good faith exception from UNITED STATES v. LEON (468 U.S. 897, 1984), and procedural standards from cases like United States v. Edgeworth (889 F.3d 350, 2018) regarding motions to suppress.

Legal Reasoning

The court meticulously dissected each of Hammond's arguments, applying relevant legal standards and precedents:

1. Suppression of Cell Site Location Information (CSLI)

Hammond contended that the district court improperly admitted CSLI obtained without a warrant, violating the Fourth Amendment as per Carpenter. The court identified three categories of CSLI in this case: historical CSLI obtained under a § 2703(d) order, historical CSLI collected by Detective Ghiringhelli, and real-time CSLI used to locate Hammond during his arrest.

• Historical CSLI under § 2703(d): Although Carpenter established that obtaining historical CSLI generally requires a warrant, the court applied the good faith exception from Leon. Since the data was collected before Carpenter and under the presumption of statutory compliance, exclusion was not warranted.
• Historical CSLI by Detective Ghiringhelli: This data was neither introduced at trial nor used to further the investigation in a way that would taint other evidence, rendering suppression unnecessary.
• Real-Time CSLI: The court analogized this to Knotts, where tracking a suspect's movements on public roads for a short duration does not equate to an unreasonable search. Given the probable cause and the emergency circumstances, the real-time CSLI did not constitute a Fourth Amendment violation.

The court also addressed the good faith exception, emphasizing that Detective Ghiringhelli acted based on the statutory allowances of § 2702 at the time of data collection, further negating the need for suppression.

2. Felon-in-Possession Jury Instruction

Hammond argued that his conviction under § 922(g) should be vacated following Rehaif, which requires proof of knowledge of felon status. The court applied a plain error review due to Hammond's failure to object during trial, weighing the error's impact on substantial rights.

Despite the incomplete jury instructions, the court found, following precedents like Maez, that the error did not constitute a miscarriage of justice. Hammond's significant criminal history made it reasonable for a jury to infer knowledge of his felon status.

3. Hobbs Act Robbery as a Crime of Violence

Challenging the classification of Hobbs Act robbery under § 924(c), Hammond referenced recent Supreme Court rulings invalidating residual clauses in related statutes. However, the court reiterated its consistent stance, supported by circuits like Anglin and Rivera, affirming that Hobbs Act robbery satisfies the elements clause of § 924(c) as a crime of violence.

The invalidation of residual clauses did not impact the elements clause, ensuring Hobbs Act robbery remains categorically a crime of violence.

4. Career Offender Enhancement under Sentencing Guidelines

Hammond contested the application of the career offender enhancement, arguing that Hobbs Act robbery should not qualify under the guideline's enumerated offenses. However, the court noted that Hammond forfeited this argument by not raising it during trial. Even under plain error review, the court found the district court's sentencing was unaffected by the error, as the sentence was based on factors independent of the Guidelines range.

Impact

The affirmation of Hammond's conviction underscores the judiciary's stance on balancing law enforcement's investigatory needs with constitutional protections against unreasonable searches. Specifically:

• Surveillance Practices: The decision clarifies the scope of permissible CSLI usage post-Carpenter, distinguishing between historical and real-time data, and reinforcing the good faith exception when statutory compliance is presumed.
• Felon-in-Possession Statutes: By upholding the necessity of knowledge of felon status post-Rehaif, the court reinforces the requirement for intentional cognizance in such charges.
• Interpretation of Crimes as Violent: The affirmation reaffirms Hobbs Act robbery's classification as a crime of violence, aligning with circuit consensus and resisting challenges based on substantive changes in related statutes.
• Sentencing Guidance Adherence: The decision highlights the procedural importance of raising sentencing arguments at trial, emphasizing the limited scope of appellate review for unraised claims.

This judgment serves as a precedent for future cases involving CSLI, felon-in-possession challenges, and the classification of aggravated robbery under criminal statutes.