United States v. DeAndre Jackson, 120 F.4th 1210

At around 1:10 AM, Officer McCauley in Collingdale, PA observed a car with a broken taillight, expired registration, and a license plate not linked to any vehicle, in a high-crime neighborhood.
The officer attempted to stop the car; the driver fled, and the vehicle was lost, but was spotted again 40 minutes later. The officer blocked the vehicle in a dead-end lot.
Facing three suspects in the vehicle (Jackson, Martins, and Winfield) and outnumbered, the officer initiated a “felony stop,” drawing his weapon and ordering the suspects out at gunpoint until backup arrived. The suspects were handcuffed and frisked.
A frisk revealed a gun magazine on Jackson; Jackson conceded there was a firearm in the car. Officers then noticed a marijuana smell, searched the car and trunk, discovering marijuana residue, drug paraphernalia, clothing matching recent robbery descriptions, and more firearms.
Both Jackson and Martins moved to suppress the evidence, arguing the stop and ensuing search were more intrusive than permitted by the Fourth Amendment. The district court denied the motions and both pled guilty, preserving their right to appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were safety measures during the stop excessive?	Officers escalated stop into an arrest without probable cause	Safety precautions justified by car theft/evasion	Officers’ actions were reasonable under the circumstances
Was the frisk of Jackson lawful?	No reasonable suspicion Jackson was armed or dangerous	Frisk was for officer safety in a tense setting	Frisk was reasonable given context and did not violate Fourth Amendment
Did defendants have standing to suppress evidence?	As vehicle occupants, they were seized and can challenge stop	Only owners/drivers have privacy interest	Both had standing to challenge seizure and suppression of evidence
Was the trunk search lawful?	No probable cause for trunk search	Supported by marijuana odor and firearm discovery	Officers had probable cause due to facts arising during the stop

Terry v. Ohio, 392 U.S. 1 (established standard for investigatory stops and frisks based on reasonable suspicion)
Wong Sun v. United States, 371 U.S. 471 (exclusionary rule for evidence derived from unlawful searches)
Illinois v. Wardlow, 528 U.S. 119 (reasonable suspicion standard for brief investigatory stops)
Maryland v. Wilson, 519 U.S. 408 (police may order passengers out of vehicle during stop)
Rakas v. Illinois, 439 U.S. 128 (standing to challenge search under Fourth Amendment)
Brendlin v. California, 551 U.S. 249 (all vehicle occupants are seized during traffic stop for Fourth Amendment purposes)
United States v. Moorefield, 111 F.3d 10 (use of force and handcuffs can be reasonable during Terry stop under specific circumstances)
Baker v. Monroe Township, 50 F.3d 1186 (brandishing guns and handcuffing may be excessive unless justified by circumstances)