United States v. Andre Slocumb, 804 F.3d 677

Around midnight officers executing a drug-search warrant staged at a closed salvage-yard parking lot known for drug activity and encountered Andre Slocumb, his girlfriend (Lewis), and an infant near two cars.
Officers observed Slocumb transfer a car seat between the cars; Lieutenant Chilton approached, thought Slocumb appeared evasive (avoiding eye contact, mumbling), and told Officer Grant to stay with them and that they were "not allowed to leave."
Grant asked for identification; Slocumb initially gave the name "Anthony Francis," which dispatch confirmed matched someone of that appearance; he declined a frisk and denied carrying illegal items.
Lewis later identified Slocumb by another name, "Hakeem," known to officers as under investigation; Grant arrested Slocumb for giving a false name and found cash on him; Lewis consented to search the Honda, which yielded methamphetamine, cocaine, and other items.
Slocumb moved to suppress the evidence and statements, arguing the initial seizure lacked reasonable suspicion, the arrest lacked probable cause, and the car search lacked valid consent; the district court denied suppression, he pleaded guilty reserving appeal, was sentenced, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to detain Slocumb (Terry stop)	Slocumb: detention lacked particularized reasonable suspicion—presence in closed lot, time of night, and his nervous manner were insufficient	Government: high-crime location, late hour, closed lot, evasive behavior and inconsistent answers provided reasonable suspicion	Court: No—totality of circumstances did not yield particularized reasonable suspicion; seizure unlawful
Whether arrest for giving a false name was supported	Slocumb: arrest tainted by unlawful seizure; false-name arrest not justified absent seizure lawfully initiated	Government: arrest valid once officers learned Lewis identified him as known suspect	Court: Because initial seizure lacked reasonable suspicion, arrest and subsequent searches cannot stand (suppression warranted)
Whether Lewis had authority to consent to search Honda	Slocumb: Lewis lacked actual or apparent authority to consent to search of vehicle	Government: Lewis’s presence and statements gave apparent authority to consent	Court: Court did not need to resolve consent because initial seizure was invalid and dispositive
Remedy for suppression denial	Slocumb: evidence and statements should be suppressed; conviction vacated	Government: denial should be affirmed	Court: Reversed denial of motion to suppress, vacated conviction and sentence, remanded for proceedings consistent with opinion

Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for investigatory stops and reasonable suspicion)
Mendenhall, 446 U.S. 544 (1980) (Mendenhall plurality: test for when a person is "seized" for Fourth Amendment purposes)
Illinois v. Wardlow, 528 U.S. 119 (2000) (presence in high-crime area plus unprovoked flight relevant but not alone dispositive)
United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances test for reasonable suspicion)
United States v. Massenburg, 654 F.3d 480 (4th Cir. 2011) (requires particularized suspicion; cautions against overreading nervous behavior)
United States v. Bumpers, 705 F.3d 168 (4th Cir. 2013) (high-crime area and evasive movement can contribute to reasonable suspicion)
United States v. Sprinkle, 106 F.3d 613 (4th Cir. 1997) (minor evasive acts insufficient for reasonable suspicion without other indicators)