Blake Andrew Mitchell, Jr. v. Commonwealth of Virginia, 1976181

At ~1:00 a.m. on Oct. 31, 2017, Officer McCarthy saw a car pass his stopped patrol vehicle, ran the plate, and learned the registered owner was Ikeya Nellun and that there was a possible warrant for her.
The DMV return included a written physical description (black female, 5'5", 155 lbs.) that, according to McCarthy, matched the driver he had just seen; he made a U-turn, followed, and initiated a traffic stop.
The driver identified herself as Keisha Hogan (matching the description); Mitchell was a front-seat passenger. Officers observed a pill container on Mitchell, he gave false ID, and was found to be wanted; he resisted arrest.
After Mitchell was removed, officers recovered drug evidence (including cocaine and hydrocodone) from the vehicle and items tied to Mitchell; he was charged and later entered conditional guilty pleas preserving the suppression issue.
The trial court denied Mitchell’s suppression motion; after interlocutory appellate proceedings and remand prompted by Kansas v. Glover, the Court of Appeals affirmed the denial, holding the stop lawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable, articulable suspicion to stop vehicle when owner had a warrant but officer had not confirmed owner was driver	Mitchell: Officer lacked sufficient particularized facts to reasonably believe the registered owner was the driver, so the stop violated the Fourth Amendment	Commonwealth: Knowledge of an outstanding warrant for the registered owner plus that the driver matched the owner's physical description gave reasonable suspicion (Hoye)	The stop was lawful under the Fourth Amendment; commonsense inference that owner may be driver supplies reasonable suspicion (following Kansas v. Glover); denial of suppression affirmed

Kansas v. Glover, 140 S. Ct. 1183 (2020) (an officer may infer the registered owner is likely the driver; that inference can supply reasonable suspicion)
Hoye v. Commonwealth, 18 Va. App. 132 (1994) (matching owner description and outstanding warrant supported stop)
Brendlin v. California, 551 U.S. 249 (2007) (vehicle stop seizes all occupants)
Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable suspicion need not be perfect; reasonable mistake can justify stop)
Navarette v. California, 572 U.S. 393 (2014) (reasonable suspicion standard explained; minimal objective justification required)
United States v. Sokolow, 490 U.S. 1 (1989) (reasonable-suspicion inquiry uses totality of circumstances)
United States v. Cortez, 449 U.S. 411 (1981) (totality of the circumstances and particularized suspicion framework)
Delaware v. Prouse, 440 U.S. 648 (1979) (stopping motor vehicles constitutes a seizure and must be reasonable)