United States v. Andre Johnson, 31 F.4th 618

Detectives investigating suspected drug trafficking identified Andre Johnson as a supplier, knew he often carried drugs and a gun in a backpack, and had a history of violent and firearm-related convictions.
Officer Rasche observed Johnson in a royal-blue Cadillac that fled from a marked squad car after a stop was attempted; plates were expired and the vehicle was linked to Johnson’s family.
About a minute after losing the car, Rasche saw Johnson walking with a backpack; uniformed officers were summoned and warned Johnson might be armed.
Officer Byntar pulled behind Johnson, drew his firearm, ordered him to drop the backpack; Johnson eventually lay face down and Sergeant Stevens handcuffed him.
Stevens smelled raw marijuana while restraining Johnson, patted him down, found marijuana, cash, and phones; officers saw packaging in the backpack and later obtained a warrant that uncovered a handgun, scale, and drugs.
The district court denied Johnson’s motion to suppress (finding reasonable suspicion and no de facto arrest); Johnson pleaded guilty but reserved the right to appeal the suppression ruling; the court of appeals affirmed.

Issue	Johnson's Argument	Government's Argument	Held
Was the stop supported by reasonable suspicion?	Past convictions and earlier alleged transaction were stale; no current suspicion.	Rasche’s investigation, known backpack habit, recent flight from police, and team knowledge gave particularized suspicion.	Yes — totality of circumstances gave reasonable suspicion for a Terry stop.
Did drawing a gun and handcuffing convert the stop into an arrest requiring probable cause?	Those measures together created a de facto arrest lacking probable cause.	Officers reasonably used force to protect safety given belief Johnson was armed and his earlier flight/noncompliance.	No — drawing a weapon and using handcuffs were reasonable and did not transform the stop into an arrest.

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes investigatory stop standard)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (flight can contribute to reasonable suspicion)
Pollreis v. Marzolf, 9 F.4th 737 (8th Cir. 2021) (totality-of-circumstances and stop-to-arrest factors)
United States v. Sanford, 813 F.3d 708 (8th Cir. 2016) (drawing weapons/handcuffs permissible during stop)
United States v. Fisher, 364 F.3d 970 (8th Cir. 2004) (officer safety can justify brandishing weapons)
United States v. Trogdon, 789 F.3d 907 (8th Cir. 2015) (combination of innocent acts can create reasonable suspicion)
United States v. Stewart, 631 F.3d 453 (8th Cir. 2011) (prior convictions may be relevant to suspicion)
Waters v. Madson, 921 F.3d 725 (8th Cir. 2019) (stop becomes arrest if unreasonably long or forceful)
United States v. Smith, 990 F.3d 607 (8th Cir. 2021) (use of handcuffs reasonable given flight/noncompliance)
United States v. Raino, 980 F.2d 1148 (8th Cir. 1992) (factors for whether stop converted to arrest)