United States v. Anthony Collins, 883 F.3d 1029

Early-morning surveillance of 9028 Oak Street in Kansas City found the garage associated with Robert Currie had been the site of prior controlled buys of methamphetamine and heavy late-night/early-morning transient traffic consistent with drug activity.
Officers observed Collins enter the garage at about 3:30–4:30 a.m., remain roughly 10–15 minutes, then leave driving a Mercury Grand Marquis.
Officers followed, activated lights after the vehicle left sight of the garage, and stopped the car after it made multiple turns and brake taps; both occupants were ordered out and detained.
An officer saw a magazine with live ammo in plain view on the driver’s seat, did a protective sweep, and recovered a loaded firearm from the glove box; a records check revealed Collins was a convicted felon.
Collins was charged with being a felon in possession of a firearm and moved to suppress evidence obtained from the warrantless stop and vehicle search; the district court denied the motion, Collins entered a conditional guilty plea, and appealed refusal to suppress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable, articulable suspicion to stop Collins's vehicle	Collins: surveillance did not show pervasive illegal activity making any visitor suspect; officers lacked evidence specifically linking Collins to drug activity; no observed sales by Officer Murphy; time alone is not indicative of trafficking	Government: totality of circumstances (prior controlled buys, informants, surveillance showing heavy late-night brief visits, Collins's entry and short stay in the known drug location) gave reasonable suspicion to investigate	Stop was supported by reasonable, articulable suspicion under the totality of circumstances; stop was lawful
Whether stop depended on alleged failure to yield to patrol car	Collins: officers lacked reasonable suspicion because he did not fail to yield when lights were activated	Government: independent reasonable suspicion existed before any failure-to-yield issue	Court did not reach the failure-to-yield argument because reasonable suspicion existed prior to the stop

Illinois v. Wardlow, 528 U.S. 119 (2000) (brief investigatory stops permitted on reasonable, articulable suspicion)
United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-the-circumstances test; officers may draw on training and experience)
United States v. Winters, 491 F.3d 918 (8th Cir. 2007) (brief stops of vehicles permissible to investigate suspected criminal activity)
United States v. Robinson, 670 F.3d 874 (8th Cir. 2012) (totality analysis and deference to officers' inferences)
United States v. Bustos-Torres, 396 F.3d 935 (8th Cir. 2005) (reasonable suspicion may exist absent knowledge of a suspect's prior criminal history)
United States v. Buchannon, 878 F.2d 1065 (8th Cir. 1989) (presence at a location under investigation can support reasonable suspicion)
United States v. Spotts, 275 F.3d 714 (8th Cir. 2002) (factors supporting belief vehicle contained drugs or evidence of drug activity)