Palma Jefferson, Jr. v. United States
FourthAmendment DueProcess CriminalProcedure
Whether the Fourth Amendment's probable cause requirement is satisfied when a search warrant issues based on an affidavit lacking objective facts, and whether a district court's refusal to address this constitutional challenge conflicts with this Court's precedents requiring meaningful judicial review of Fourth Amendment claims
I. Fourth Amendment: Warrant and Entry Defects 1. Whether the Fourth Amendment's probable cause requirement is satisfied when a search warrant issues based on an affidavit lacking objective facts, and whether a district court's refusal to address this constitutional challenge conflicts with this Court's precedents requiring meaningful judicial review of Fourth Amendment claims, including Beck v. Ohio, 379 U.S. 89 (1964); Johnson v. United States, 333 U.S. 10 (1948); and Ybarra v. Illinois, 444 U.S. 85 (1979). 2. Whether the Fourth Amendment is violated when law enforcement officers gain entry to a residence by falsely representing to a property manager that they possessed a warrant when in fact no warrant had been applied for or issued, and subsequently obtain evidence before execution of any warrant, as substantiated by photographic timestamps, corroborating police dispatch logs, and sworn testimony; and whether due process is violated when the government falsely attributes the warrantless search to a "daylight savings setting" not found in the camera's user manual, contradicted further by VeriPic's metadata confirmation that the internal camera clock was accurate at the time of upload, and the district court refuses to conduct any legal analysis or fact-finding of this challenge. 3. Whether the Fourth Amendment and the Sixth Amendment Confrontation Clause are violated when a warrant affidavit, and suppression-hearing testimony describe information from a "reliable source," even further supported by the police reports as a "reliable confidential source," and the government later recharacterizes that source as an "anonymous tip" at trial, and the district court upholds the warrant without addressing the contradiction or affording the defendant an opportunity to confront or test the credibility of the source—even though the information attributed to that source never materialized and demonstrated unreliability —contrary to this Court's precedents in Illinois v. Gates, 462 U.S. 213 (1983); Florida v. J.L., 529 U.S. 266 (2000); Crawford v. Washington, 541 U.S. 36 (2004); and Napue v. Illinois, 360 U.S. 264 (1959). 9 II. Due Process and Fair Trial: Judicial and Evidentiary Failures 4. Whether due process is violated when the government's lead witness testifies at the suppression hearing that he contacted the source at his captain's instruction because the source supposedly knew of a drug run that never occurred, yet at trial identifies the basis as an anonymous tip, and the district court rules on suppression as if it were an anonymous tip without acknowledging the police reports referred it to a reliable confidential source, and the affidavit's sworn statement that it was a reliable source. 5. Whether a defendant is denied the constitutional right to a fair trial under the Fifth and Sixth Amendments when the presiding district judge declares in open court during trial, before the jury's verdict, that the defendant is guilty, thereby undermining judicial neutrality and the appearance of impartiality required under this Court's precedents, as confirmed by the trial transcripts that the district court failed to address. III. Sixth Amendment: Ineffective Assistance of Counsel 6. Whether the Sixth Amendment right to effective assistance of counsel is violated when trial counsel fails to raise or preserve fundamental constitutional challenges — including a warrant affidavit lacking probable cause, unlawful pre-warrant entry obtained by false representation, government misrepresentations regarding evidence irregularities, contradictions in key witness testimony, and judicial bias—that, if properly litigated, would have undermined the validity of the conviction. 10