United States v. Brandon Burgess, 759 F.3d 708

Late Sunday-night shooting reports in a Chicago neighborhood led police to investigate nearby areas.
Two officers stopped Burgess’s car a mile from a reported shooting after observing a black car in the area.
Burgess was a passenger; a revolver was found on his seat with most rounds expended.
Discrepancies in officers’ testimony about recognition and car details did not overturn the district court’s factual findings.
The district court denied Burgess’s suppression motion, ruling the stop was supported by reasonable suspicion based on dispatch information and circumstances.
Burgess pleaded guilty conditionally and appeals the denial of suppression of the gun evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dispatcher hearsay can create reasonable suspicion	Burgess argues no; unreliable tips alone insufficient	United States contends multiple independent 911 tips establish reliability	Yes; corroborated tips support suspicion
Whether stopping a black car miles from the shooting is justified	Burgess invokes Bohman: color alone is insufficient	United States emphasizes totality of circumstances and imminent danger	Yes; totality supports stop given danger, timing, color, location, and traffic conditions

Florida v. J.L., 529 U.S. 266 (U.S. 2000) (anonymous tip may supply reasonable suspicion with reliability indicia)
United States v. Arvizu, 534 U.S. 266 (Sup. Ct. 2002) (totality of the circumstances standard)
United States v. Bohman, 683 F.3d 861 (7th Cir. 2012) (stop based on mere suspicion of activity at a place inadequate)
United States v. Johnson, 170 F.3d 708 (7th Cir. 1999) (mere generalized tips insufficient without particularized suspicion)
United States v. Brewer, 561 F.3d 676 (7th Cir. 2009) (imminent danger reduces required suspicion for stop)