## Facts

- Willie E. Lloyd, a convicted felon, was indicted under 18 U.S.C. § 922(g)(1) for possessing a 9mm Ruger semiautomatic pistol.
- A confidential informant (a Vice Lords member) told Chicago police that Lloyd possessed two loaded handguns (a 9mm Ruger and a 9mm Glock) at a specific first-floor apartment on West Jackson Street and described where Lloyd kept them (a shelf in a rear-bedroom closet).
- Detective Wojcik corroborated the informant’s location and apartment description by visiting the site with the informant, who identified the building and apartment windows; the informant also identified Lloyd from photographs.
- Police records confirmed Lloyd’s felony history, including violent and weapons-related convictions.
- A warrant issued to search Lloyd’s apartment and person; during execution, officers found Lloyd inside.
- Officers testified that Lloyd broke a window and threw a handgun outside as police entered; the handgun was recovered outside the window.
- Lloyd allegedly stated upon arrest: “You got me. My brothers should have been out there.”
- Two teenagers were found in Lloyd’s bedroom; one testified they served as Lloyd’s security/bodyguards.
- The prosecution introduced a gang specialist’s testimony that Lloyd led a street-gang faction, used members as security, and had survived recent assassination attempts; the district court admitted this testimony for limited purposes and instructed the jury accordingly.
- After conviction, the district court imposed a two-level obstruction-of-justice enhancement under U.S.S.G. § 3C1.1 based on a finding that Lloyd testified falsely on a material matter.

## Issues

1. Whether the search warrant was supported by probable cause where it relied on a known informant’s detailed, firsthand account corroborated by police.
2. Whether the district court abused its discretion under Federal Rules of Evidence 403 and 404(b) by admitting gang-related and violence-related testimony to show motive, context, and relationships.
3. Whether the district court clearly erred in applying a U.S.S.G. § 3C1.1 obstruction-of-justice enhancement based on perjury.

## Decision

- The Seventh Circuit affirmed the conviction and sentence.
- The court held the warrant was supported by probable cause under the totality of the circumstances, and the magistrate had a substantial basis to issue it.
- The court held the district court did not abuse its discretion by admitting limited gang-related evidence with cautionary instructions because it was relevant to motive and context and not unfairly prejudicial.
- The court upheld the obstruction enhancement, concluding the perjury finding was not clearly erroneous and crediting the trial judge’s credibility assessment.

## Legal Principles

- Probable cause may be established by a known informant’s detailed, firsthand observations, particularly when police corroborate significant details and a magistrate’s determination is given substantial deference.
- Gang-affiliation evidence is not categorically inadmissible; it may be admitted to prove motive, explain relationships, or provide context for statements or conduct, subject to Rule 403 balancing and limiting instructions.
- Evidence touching on other acts may be admissible under Rule 404(b) when offered for non-character purposes (e.g., motive, background, context) and accompanied by appropriate limiting instructions.
- A two-level increase under U.S.S.G. § 3C1.1 is proper when the defendant willfully gives materially false testimony; appellate review of the perjury finding is for clear error with deference to the trial court’s credibility determinations.

## Conclusion

The Seventh Circuit affirmed because the informant’s detailed tip, corroborated by police, supported probable cause for the warrant; the gang-related testimony was properly limited to relevant non-character purposes with jury instructions; and the obstruction enhancement was supported by the trial court’s finding of willful, material false testimony.


United States v. Lloyd, 71 F.3d 1256 (7th Cir. 1995)