United States v. Chauncey Jones
1f4th50
| D.C. Cir. | 2021Background
- MPD ShotSpotter alerted officers to gunfire on the 3500 block of 13th Street SE; officers arrived about 1.5 minutes after the alert.
- Officers Turner and Ennis found no victims and observed Chauncey Jones as the only person outside on the block, walking briskly away.
- Jones did not initially respond to repeated calls from Officer Turner; when he paused he removed headphones and officers observed his hand moving toward his waistband.
- Officer Williams tackled Jones after seeing an item jostle in Jones’s waistband and recovered a pistol; Jones is a convicted felon and was charged under 18 U.S.C. § 922(g)(1).
- Jones moved to suppress the gun as the product of an unlawful Terry stop; the district court denied suppression, held a stipulated bench trial, convicted and sentenced Jones, and he appealed the suppression ruling.
Issues
| Issue | Jones's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to stop Jones | Stop lacked reasonable suspicion; presence on the block and his conduct were innocent possibilities | ShotSpotter pinpointed shots to the block, Jones was the only person outside, he walked away and failed to respond — reasonably suspicious | Court: Totality of circumstances gave reasonable, articulable suspicion; denial of suppression affirmed |
| Whether ShotSpotter provided sufficient geographic specificity | ShotSpotter signals are a vague radius, so officers couldn't know shots were on that precise block | District court credited government testimony that ShotSpotter identified the 3500 block; officers reasonably relied on that | Court: District court's factual finding that ShotSpotter pinpointed the block was not clearly erroneous; permissibly relied upon |
| Whether officers had to rule out indoor firing or other innocent explanations | Shots could have been indoors or others could have left; officers must not stop based on mere presence | Officers arrived quickly, had corroborating 911 reports, and observed evasive conduct—officers need not eliminate all innocent explanations | Court: Officers may draw reasonable inferences; harmless residual possibilities do not defeat reasonable suspicion |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (Terry-stop standard: specific and articulable facts supporting reasonable suspicion)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (presence in high-crime area plus unprovoked flight can support reasonable suspicion)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-circumstances analysis; need not rule out innocent explanations)
- United States v. Brown, 334 F.3d 1161 (D.C. Cir. 2003) (presence in precisely identified crime location plus furtive movements can create reasonable suspicion)
- United States v. Delaney, 955 F.3d 1077 (D.C. Cir. 2020) (vacated reasonable-suspicion finding where shots came from multiple directions and officers saw defendant before surveying area)
- United States v. Rickmon, 952 F.3d 876 (7th Cir. 2020) (describing ShotSpotter as GPS-enabled acoustic sensors used to record gunshots)