United States v. Dazhan McCallister, 39 F.4th 368

Talbot Whitney Park in Akron was known as a high-crime location with recent firearms and drug activity.
Police received an anonymous tip a group of men were smoking marijuana in the park; officers later observed a group of 10–15 men there.
As officers approached, they detected the odor of marijuana near the group.
Officers ordered several men, including Dazhan McCallister, to stop; McCallister attempted to walk away and then complied by placing his hands on his head.
Detective Elam observed a "bump" on McCallister’s right side and saw McCallister turn to shield his front; when McCallister raised his hands, a firearm magazine became visible and Elam recovered a Glock 9mm converted to a machinegun.
McCallister moved to suppress the firearm as the product of an unlawful stop/frisk; the district court denied suppression, McCallister pleaded guilty while preserving appeal, and the Sixth Circuit affirmed.

Issue	McCallister's Argument	Government's Argument	Held
Was the Terry stop supported by reasonable suspicion that McCallister had smoked marijuana?	The suspicion was not particularized to him because the odor emanated from a group and could have been a legal substance (hemp).	Anonymous tip corroborated by officers’ observations and officers smelled marijuana near the group; McCallister tried to walk away, supporting individualized suspicion.	Stop was supported by reasonable suspicion under the totality of circumstances.
Was the frisk/search for weapons justified?	No — frisk lacked individualized reasonable suspicion and Ohio law allows open carry.	Officer observed a bulge, saw a magazine when McCallister raised his shirt, McCallister turned to conceal, and park was high-crime; these supported suspicion the suspect was armed and dangerous.	Frisk/search was reasonable; seizure of firearm lawful.

Terry v. Ohio, 392 U.S. 1 (establishes constitutionality of investigative stops and frisks)
Sokolow v. Florida, 490 U.S. 1 (describes reasonable suspicion standard for Terry stops)
Navarette v. California, 572 U.S. 393 (anonymous tip can supply reasonable suspicion when sufficiently reliable)
Illinois v. Wardlow, 528 U.S. 119 (flight or attempting to leave as factor supporting reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (totality-of-circumstances approach; reject divide-and-conquer)
United States v. Cortez, 449 U.S. 411 (requirement of particularized suspicion for stops)
Pennsylvania v. Mimms, 434 U.S. 106 (officer safety justifies limited searches after lawful stops)
Michigan v. Long, 463 U.S. 1032 (frisk justified when officer reasonably suspects weapon that could put them in danger)
United States v. Sheckles, 996 F.3d 330 (6th Cir.: officer’s detection of marijuana odor supports reasonable suspicion)
United States v. Brooks, 987 F.3d 593 (6th Cir.: marijuana odor can support Terry stop)