United States v. Christopher Sanchez
21-1002
| 3rd Cir. | Jul 7, 2021Background
- Detective Gaetan MacNamara, who had an eight‑year history of encounters with Christopher Sanchez, checked the DELJIS database and repeatedly found no Delaware driver’s license for Sanchez. A confidential informant had also told MacNamara, two months earlier, that Sanchez had a black handgun and drove a gray Mitsubishi SUV.
- MacNamara observed Sanchez driving an SUV matching the tip and initiated a traffic stop on suspicion of driving without a license.
- After Sanchez initially stopped, he accelerated a few feet and was boxed in by a second patrol car; MacNamara then approached, opened the driver’s door, and a handgun was observed on the driver’s side floorboard (sequence disputed, but both sides agreed a gun was there).
- Officers removed, handcuffed, and arrested Sanchez; a grand jury indicted him under 18 U.S.C. §§ 922(g)(1) and 924(a)(2).
- The District Court denied Sanchez’s motion to suppress the firearm; Sanchez pleaded guilty and appealed the suppression ruling.
- The Third Circuit affirmed, addressing reasonable suspicion for the stop, whether the stop became an arrest, and whether the gun was in plain view.
Issues
| Issue | Sanchez's Argument | Government's Argument | Held |
|---|---|---|---|
| 1) Was the traffic stop supported by reasonable suspicion? | MacNamara lacked reasonable suspicion because DELJIS does not show licensure in every state and he should have confirmed non‑licensure before approaching. | DELJIS searches repeatedly showed no Delaware license; database info plus commonsense judgment gave minimal objective justification to stop. | Stop was supported by reasonable suspicion (database results and prior info suffice). |
| 2) Did the stop ripen into a full arrest (requiring probable cause)? | Boxing in the vehicle, opening the door with drawn gun, and restraining Sanchez converted the stop into an arrest. | Officers may take measures to secure safety and the scene during an investigative stop; given Sanchez’s history, reported armament, and attempted driving forward, those measures were reasonable. | Actions were consistent with a Terry stop; did not automatically become a full arrest. |
| 3) Was the handgun admissible under the plain‑view doctrine? | The seizure was unlawful because the stop/arrest was unlawful, and the gun was not properly in plain view. | The stop was lawful, the gun’s incriminating nature was immediately apparent (given Sanchez’s prior conviction), and officers lawfully viewed and accessed the gun. | Plain‑view requirements satisfied; seizure lawful. |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (1979) (stopping a vehicle lawful when officer reasonably suspects unlicensed driving)
- Kansas v. Glover, 140 S. Ct. 1183 (2020) (officers may rely on database info and commonsense probabilities to form reasonable suspicion)
- United States v. Delfin‑Colina, 464 F.3d 392 (3d Cir. 2006) (reasonable suspicion required for traffic stops)
- United States v. Johnson, 592 F.3d 442 (3d Cir. 2010) (blocking a vehicle and approaching with weapons does not automatically constitute an arrest)
- Terry v. Ohio, 392 U.S. 1 (1968) (officers may take reasonable steps for safety during investigative stops)
- Horton v. California, 496 U.S. 128 (1990) (plain‑view seizure elements)
- United States v. Menon, 24 F.3d 550 (3d Cir. 1994) (application of the plain‑view test)
- United States v. Donahue, 764 F.3d 293 (3d Cir. 2014) (probable cause to search vehicle where weapon’s incriminating nature is apparent)
- Texas v. Brown, 460 U.S. 730 (1983) (shining a light into a vehicle to view interior is not a Fourth Amendment search)