Opinion

United States v. Brown

Court
Court of Appeals for the Fifth Circuit
Filed
Feb 14, 2025
Status
Unpublished
Nature of suit
Direct Criminal
Cited by
0 cases
Authority
More cited than 34.0%

The opinion

Case: 24-50126 Document: 71-1 Page: 1 Date Filed: 02/14/2025

United States Court of Appeals

for the Fifth Circuit United States Court of Appeals

Fifth Circuit

____________ FILED

February 14, 2025

No. 24-50126

Lyle W. Cayce

Summary Calendar Clerk

____________

United States of America,

Plaintiff—Appellee,

versus

Jameel Alexander Brown,

Defendant—Appellant.

______________________________

Appeal from the United States District Court

for the Western District of Texas

USDC No. 5:21-CR-193-1

______________________________

Before Graves, Willett, and Wilson, Circuit Judges.

Per Curiam:*

Jameel Alexander Brown was sentenced to 52 months of

imprisonment after pleading guilty to theft of mail, in violation of 18 U.S.C.

§ 1708; and possession of a firearm after a felony conviction, in violation of

18 U.S.C. § 922(g)(1). On appeal, he contends that the district court erred

_____________________

*

This opinion is not designated for publication. See 5th Cir. R. 47.5.

Case: 24-50126 Document: 71-1 Page: 2 Date Filed: 02/14/2025

No. 24-50126

in denying his motion to suppress, arguing that the responding officer lacked

reasonable suspicion of illegal activity.

When reviewing the denial of a motion to suppress, we review the

district court’s legal conclusions de novo and its factual determinations for

clear error. United States v. Alkheqani, 78 F.4th 707, 715 (5th Cir. 2023).

Whether an officer had reasonable suspicion for an investigatory stop is a

question of law that is reviewed de novo. United States v. Alvarez, 40 F.4th

339, 344 (5th Cir. 2022). The evidence is viewed in the light most favorable

to the prevailing party—here, the Government. See Alkheqani, 78 F.4th at

715. The district court’s ruling will be upheld “if there is any reasonable view

of the evidence to support it.” Alvarez, 40 F.4th at 344 (internal quotation

marks and citation omitted). However, “where testimony conflicts with

video evidence, our court must view the facts in the light depicted by the

videotape.” United States v. Wright, 57 F.4th 524, 530 (5th Cir. 2023)

(internal quotation marks and citation omitted).

Brown argues that the responding officer lacked reasonable suspicion

of illegal activity because the officer could not tell whether Brown met the

suspect’s physical description when the officer activated his patrol vehicle’s

overhead lights. The record reflects that a witness called 911 and reported

that he observed a man breaking into residential mailboxes near his home,

described the man’s appearance, and noted that the perpetrator was driving

a four-door sedan. Shortly after the crime was reported, the responding

officer saw Brown, a man matching the witness’s description, tampering with

a block of mailboxes approximately two blocks away from where the witness

had reported seeing the perpetrator. The officer also observed that a four-

door sedan was parked nearby with its engine running. While Brown

contends that the responding officer’s testimony is contradicted by video

evidence, the video does not conflict with the testimony. Because a

reasonable view of the evidence supports the district court’s finding that the

2

Case: 24-50126 Document: 71-1 Page: 3 Date Filed: 02/14/2025

No. 24-50126

responding officer had reasonable suspicion to detain Brown, the district

court did not err in denying the motion to suppress. See Alkheqani, 78 F.4th

at 715.

AFFIRMED.

3

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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