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United States Court of Appeals for the Second Circuit
January 12, 2017, Argued; July 6, 2018, Final Submission; April 1, 2019, Decided
Docket Nos. 15-958-cr(L), 15-1175-cr(CON)
[*722] Chin, Circuit Judge:
Defendants-appellants James Lyle and Michael Van Praagh appeal from judgments of the United States District Court for the Southern District of New York (Crotty, J.) convicting them on charges relating to the distribution of methamphetamine. Lyle challenges the admission at trial of evidence seized during a December 11, 2013 inventory search of a rental car and a January 9, 2014 search of his hotel room. He also challenges the admission at trial of certain post-arrest and proffer statements. Van Praagh challenges the sufficiency of the evidence of his participation in a methamphetamine distribution conspiracy, the admission of Lyle's post-arrest and proffer statements in their joint trial, and the reasonableness of his sentence. Because we conclude that the evidence at trial was sufficient to support all convictions, the challenged searches and seizures did not violate the Fourth Amendment, the admission of Lyle's statements did not violate the Fifth Amendment, and Van Praagh's sentence was reasonable, we affirm the judgments of the district court.
I. The Facts
Because Van Praagh and Lyle appeal convictions following a jury trial, we view the [**3] evidence in "the light most favorable to the government, crediting any inferences that the jury might have drawn in its favor." United States v. Rosemond, 841 F.3d 95, 99-100 (2d Cir. 2016) (quoting United States v. Dhinsa, 243 F.3d 635, 643 (2d Cir. 2001)).
Throughout 2013, Van Praagh regularly sold pound quantities of methamphetamine. These deals generally occurred once a week and often took place in Manhattan hotels. Van Praagh also sold smaller quantities of methamphetamine out of his apartment in Queens and through in-person deliveries to his customers. Brandon Hodges, an Arizona-based methamphetamine supplier, sent Van Praagh methamphetamine on three or four occasions during this time, with the largest shipment containing four ounces of methamphetamine. Van Praagh regularly sold methamphetamine to Lyle, who was also a methamphetamine dealer in the New York area. Lyle regularly sold methamphetamine to Anthony Tarantino. Tarantino initially purchased methamphetamine for personal use, but eventually started selling small quantities of methamphetamine to his own clients. Both Hodges and Tarantino cooperated with the government and testified at trial.
In January 2013, Lyle introduced Tarantino to Van Praagh. Tarantino accompanied Lyle to Van Praagh's apartment so that Lyle could restock his [**4] methamphetamine supply. While at Van Praagh's apartment, Tarantino saw Lyle purchase methamphetamine from Van Praagh, which Lyle later sold to Tarantino. In April 2013, Lyle took Tarantino to Van [*723] Praagh's apartment a second time, where Tarantino again observed Lyle "re-up," i.e., purchase methamphetamine, from Van Praagh. After this second visit, Tarantino and Van Praagh became romantically involved, and eventually Tarantino moved in with Van Praagh and began helping him sell methamphetamine.
Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.
919 F.3d 716 *; 2019 U.S. App. LEXIS 9457 **
UNITED STATES OF AMERICA, Appellee, v. JAMES LYLE, AKA SEALED DEFENDANT 3, MICHAEL VAN PRAAGH, AKA SEALED DEFENDANT 1, Defendants-Appellants, ANTHONY TARANTINO, AKA SEALED DEFENDANT 2, Defendant.
Subsequent History: US Supreme Court certiorari denied by Lyle v. United States, 140 S. Ct. 846, 205 L. Ed. 2d 470, 2020 U.S. LEXIS 46 (U.S., Jan. 13, 2020)
Prior History: [**1] ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. Consolidated appeals from judgments of the United States District Court for the Southern District of New York (Crotty, J.) entered after defendants-appellants James Lyle and Michael Van Praagh were convicted at trial of charges relating to drug trafficking. Lyle challenges the admission of (1) physical evidence obtained pursuant to warrantless searches and (2) his post-arrest and proffer statements. Van Praagh challenges (1) the sufficiency of the evidence of conspiracy, (2) the admission of Lyle's post-arrest and proffer statements in their joint trial, and (3) the reasonableness of his sentence.
United States v. Van Praagh, 2014 U.S. Dist. LEXIS 140581 (S.D.N.Y., Oct. 1, 2014)
methamphetamine, rental car, proffer, district court, redacted, driver, impoundment, arrest, conspiracy, sentence, driving, circumstances, post-arrest, license, reasonable expectation of privacy, unauthorized, distribute, standardized, drugs, quantities, dealer, co-defendant's, elicited, confession, trigger, girlfriend, possessing, rental, seized, knife
Constitutional Law, Fundamental Rights, Search & Seizure, Scope of Protection, Evidence, Burdens of Proof, Allocation, Criminal Law & Procedure, Expectation of Privacy, Warrantless Searches, Community Caretaking, Standing, Vehicle Searches, Impounded Vehicles, Seizure of Things, Admissibility, Statements as Evidence, Pleas & Related Statements, Hearsay, Exemptions, Confessions, Standards of Review, Abuse of Discretion, Evidence, Relevance, Exclusion of Relevant Evidence, Confusion, Prejudice & Waste of Time, Conduct Evidence, Prior Acts, Crimes & Wrongs, Criminal Offenses, Inchoate Crimes, Conspiracy, De Novo Review, Sufficiency of Evidence, Delivery, Distribution & Sale, Conspiracy, Elements, Plain Error, Jury Instructions, Appeals, Abuse of Discretion, Sentencing, Proportionality & Reasonableness Review