Walker v. United States

Summary

The D.C. Court of Appeals affirmed Matthew Walker's bench-trial convictions for first-degree murder while armed and related offenses, holding that surveillance footage, DNA on the tracksuit, mask, and pistol recovered along the shooter's flight path, and a note bearing his phone number collectively sufficed to prove identity beyond a reasonable doubt despite mixed-source DNA profiles and Walker's setup theory. The court also held that the absence of any evidence of motive did not render the evidence insufficient because motive is not an element of the charged offenses. The court granted the government's unopposed motion and vacated Walker's conviction for possession of a large-capacity ammunition feeding device, following its longstanding practice of accepting unopposed concessions and expressly declining to decide the statute's constitutionality, which is pending en banc; it remanded for entry of a new judgment and commitment order. Associate Judge Beckwith concurred to flag that the ballistics expert's source-attribution testimony would have been inadmissible under Geter had the issue been preserved, and Senior Judge Ruiz dissented in part, urging deferral of the motion to vacate until the en banc court decides Benson.