United States v. Anthony W. Knights, 967 F.3d 1266

~1:00 a.m.: Officers observed Anthony Knights and Hozell Keaton leaning into a parked Oldsmobile in a front yard and suspected they might be stealing the car.
Officers parked a patrol car near the Oldsmobile (with room to drive away) and approached; Keaton walked away and entered the house.
When Knights opened the driver’s door, an officer smelled burnt marijuana; Knights produced identification and said the marijuana was gone.
Officers searched Knights and the vehicle, finding pills, a ski mask, a scale, marijuana residue, a handgun, a rifle, and ammunition; Knights was arrested and later admitted owning the handgun.
Knights was indicted as a felon in possession, moved to suppress arguing the officers made an investigatory stop without reasonable suspicion; the magistrate recommended suppression but the district court denied; the Eleventh Circuit affirmed, holding the initial encounter was consensual.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers conducted an investigatory stop (a Fourth Amendment "seizure") when they parked near and approached Knights, requiring reasonable suspicion	Knights: parking/approach and officers’ conduct restrained his liberty so the encounter was a stop without reasonable suspicion; evidence is fruit of unlawful seizure	Government: the encounter was a consensual police-citizen interaction (no seizure); alternatively, officers had reasonable suspicion once they investigated	Court: The encounter was consensual and not a seizure; no Fourth Amendment violation before the odor of marijuana; conviction affirmed

United States v. Drayton, 536 U.S. 194 (U.S. 2002) (approaching and questioning in public can be consensual; no suspicion required)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual encounters do not implicate Fourth Amendment)
Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (investigatory stop requires restraint by physical force or show of authority)
United States v. Mendenhall, 446 U.S. 544 (U.S. 1980) (reasonable-person test for whether a seizure occurred)
Miller v. Harget, 458 F.3d 1251 (11th Cir. 2006) (parking behind a car and approaching on foot need not be coercive absent other shows of authority)
United States v. Beck, 602 F.2d 726 (5th Cir. 1979) (parking alongside a suspect’s car can restrain movement and effect a stop)
United States v. Perez, 443 F.3d 772 (11th Cir. 2006) (factors relevant to whether a seizure occurred)
United States v. Jordan, 635 F.3d 1181 (11th Cir. 2011) (investigatory stop standards)
Michigan v. Chesternut, 486 U.S. 567 (U.S. 1988) (use objective reasonable-person standard to assess coercion)