Edward Morgan, Jr. v. United States, 121 A.3d 1235

Citizen (Dept. of Homeland Security employee) reported seeing a short Black male with dreadlocks on a red bicycle exchange small objects with another man and "reach into the back of his pants and pull something out and put it back in."
Officers located Edward Morgan ~30 seconds after a follow-up call in the 1500 block of P Street NW; Morgan was on a red bicycle and matched other descriptive details.
Officers asked to speak with Morgan; he admitted possessing K-2 (synthetic cannabinoid) and consented to a search; officers felt an object at the back waistband, handcuffed him, and Morgan then retrieved and dropped crack cocaine from his back pants area.
Morgan moved to suppress, arguing the stop lacked reasonable articulable suspicion (Terry) and that questioning violated Miranda; trial court denied suppression and he was convicted after a stipulated trial.
The D.C. Court of Appeals affirmed the denial of the suppression motion, concluding the citizen tip + described reaching into the back of pants provided reasonable suspicion; the court declined to reach Miranda because no specific incriminating statement was identified as improperly used.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable articulable suspicion to perform a Terry stop	Morgan: citizen tip was vague/ambiguous (no drugs/money observed); reaching into "back of pants" is innocuous and does not supply reasonable suspicion	Government: identified, in-person citizen tip describing a suspected hand-to-hand exchange and a reach into the back of pants (naturally read as waistband/crotch) gave officer objective basis for a stop	Affirmed: tip was sufficiently reliable and the reaching gesture during an exchange plausibly indicated criminal activity, supplying reasonable suspicion for a Terry stop
Whether Miranda error requires reversal/suppression	Morgan: questioning violated Miranda	Government: no specific incriminating statement was identified as used at trial; K-2 admission not relied on at conviction	Not addressed on the merits; court declined to reach Miranda because no particular Miranda-tainted statement was shown to have affected the stipulated conviction

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (authorizes brief investigatory stops on reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (reasonable-suspicion is a low threshold; ambiguous conduct can justify brief detention to resolve uncertainty)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires Miranda warnings)
Jefferson v. United States, 906 A.2d 885 (D.C. 2006) (reaching into crotch/waistband during apparent exchange can support probable cause/strong inference of drug concealment)
Bennett v. United States, 26 A.3d 745 (D.C. 2011) (review of suppression rulings: view evidence in the light most favorable to prevailing party)
Milline v. United States, 856 A.2d 616 (D.C. 2004) (deference to trial court and drawing reasonable inferences for suppression rulings)
Umanzor v. United States, 803 A.2d 983 (D.C. 2002) (reasonable suspicion does not require ruling out innocent behavior)
Duhart v. United States, 589 A.2d 895 (D.C. 1991) (ambiguous conduct with many innocent explanations insufficient for Terry stop)