United States v. Demetrius Brooks, 987 F.3d 593

Late-night traffic stop of a Jeep after officers observed the front passenger (Torres) not wearing a seatbelt; officers pulled the vehicle over.
As officers approached, they smelled marijuana and Officer Anthony observed Brooks (rear passenger) make a "stuffing motion" under his seat.
Officers ordered occupants out, searched the vehicle, and recovered a loaded handgun (serial scratched) protruding between the rear seat and floorboard, marijuana, a suspected marijuana cigarette, and $723.
Brooks was charged and convicted under 18 U.S.C. § 922(g)(1) (felon in possession); he stipulated to status and interstate-commerce elements but contested possession.
After the verdict, the lone African-American juror emailed the court saying she had been pressured into voting guilty; Brooks sought an evidentiary hearing and new trial under Peña-Rodriguez.
The district court denied Brooks’s motion to suppress and his Peña-Rodriguez request and sentenced him; the Sixth Circuit affirmed.

Issue	Plaintiff's Argument (Brooks)	Defendant's Argument (United States)	Held
Fourth Amendment: validity of stop and search	Stop was unreasonable; seatbelt observation was pretext and show of force (multiple officers) made seizure coercive	Officers had probable cause to stop for seatbelt infraction; marijuana odor and stuffing motion gave probable cause to search; officers could order occupants out and multiple officers did not make seizure unreasonable	Stop and warrantless vehicle search were reasonable; occupants lawfully ordered out; number of officers not dispositive
Sufficiency of evidence: possession under § 922(g)(1)	No proof Brooks knowingly possessed the gun; mere presence is insufficient	Officer saw stuffing motion, gun found exactly where Brooks stuffed something — circumstantial evidence of actual (physical) control	Evidence sufficient for a rational juror to find Brooks knowingly possessed the firearm; no minimum duration of control required
Juror misconduct / Peña‑Rodriguez	Juror’s post‑verdict email (juror pressured, lone Black juror) permits evidentiary hearing to probe racial bias under Peña‑Rodriguez	Email contained no race‑based comments; Rule 606(b) bars inquiry into deliberations absent Peña‑Rodriguez’s narrow exception, which requires overt racial statements showing animus	Denial of hearing and new trial affirmed: Peña‑Rodriguez not triggered because no clear overt racial statements implicating bias

Whren v. United States, 517 U.S. 806 (1996) (objective basis governs traffic stops; pretextual motives irrelevant)
Carroll v. United States, 267 U.S. 132 (1925) (warrantless vehicle searches permissible with probable cause)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable‑suspicion stops and limited intrusions)
California v. Acevedo, 500 U.S. 565 (1991) (probable cause justifies warrantless vehicle search)
Peña‑Rodriguez v. Colorado, 137 S. Ct. 855 (2017) (constitutional exception to no‑impeachment rule for clear racial‑bias statements)
Rehaif v. United States, 139 S. Ct. 2191 (2019) (elements of § 922(g) include defendant's knowledge of status)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (officers may order occupants out of a lawfully stopped vehicle)
United States v. Johnson, 707 F.3d 655 (6th Cir. 2013) (odor of marijuana can establish probable cause for vehicle search)
United States v. Morrison, 594 F.3d 543 (6th Cir. 2010) (proximity and immediate control can support finding of actual possession)
United States v. Garcia, 758 F.3d 714 (6th Cir. 2014) (circumstantial evidence can prove actual possession)
United States v. Birmley, 529 F.2d 103 (6th Cir. 1976) (mere presence/association insufficient to prove possession)