United States v. Carl Jefferson
698 F. App'x 762
| 4th Cir. | 2017Background
- Carl Armstead Jefferson Jr. was indicted on federal charges including possession with intent to distribute cocaine base and heroin, being a felon in possession of a firearm, and possessing a firearm in furtherance of drug trafficking.
- Jefferson moved to suppress evidence seized during his arrest; the district court denied the motion after an evidentiary hearing.
- Jefferson pleaded guilty to two counts (possession with intent to distribute cocaine base and possession of a firearm in furtherance of a drug crime) while preserving his right to appeal the suppression denial.
- Law enforcement observed activity in a parking lot they knew was used for daytime drug transactions: several occupied cars, occupants looking at phones and a particular entrance, and occupants noticing Jefferson’s arrival.
- Jefferson signaled other occupants to join him in the adjacent lot; the parked cars then moved and followed Jefferson into that lot.
- The Fourth Circuit reviewed the denial of suppression de novo as to reasonable suspicion, giving deference to the district court’s factual findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to detain Jefferson | Jefferson argued the stop lacked reasonable, articulable suspicion and was based on an impermissible hunch | Government argued the totality of circumstances (officers’ drug-area knowledge, car/occupant behavior, Jefferson’s signaling, and cars following) supported reasonable suspicion | Court held there was reasonable suspicion to detain Jefferson and affirmed the denial of the suppression motion |
Key Cases Cited
- United States v. Palmer, 820 F.3d 640 (4th Cir. 2016) (deference to district court factual findings and crediting officer experience in reasonable-suspicion analysis)
- United States v. Foster, 634 F.3d 243 (4th Cir. 2011) (Fourth Amendment requires reasonable, articulable suspicion for investigative stops)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (officer must articulate more than an unparticularized hunch)
- United States v. Perkins, 363 F.3d 317 (4th Cir. 2004) (totality of the circumstances and aggregation of otherwise innocent factors can create reasonable suspicion)
- United States v. Branch, 537 F.3d 328 (4th Cir. 2008) (review of reasonable suspicion should be commonsensical and account for officers’ particular experience)