United States v. Devion Williams, 929 F.3d 539

Undercover Officer Justin Palmer (investigating stolen cars) saw a purple Dodge Challenger listed as stolen on department “hot sheets” and verified its VIN as stolen.
Palmer misread the hot sheet and believed a red Dodge Challenger (actually a red Dodge Charger was the other stolen vehicle) was also stolen; he and another officer surveilled a red Challenger that briefly stopped beside the purple stolen car.
Officers followed the red Challenger to a driveway, handcuffed Williams and two others for officer safety, and ran the VIN and plate checks, which showed the red Challenger was not stolen but had expired temporary tags.
Within minutes after the checks, officers observed baggies they suspected were drugs and saw a handgun in plain view in the passenger seat; they removed the gun and learned it was stolen.
Because no one claimed ownership and statements about the vehicle were evasive/untruthful, officers decided to tow the car and conducted an inventory search that uncovered a second loaded handgun; DNA later linked Williams to that firearm and to crack cocaine.
Williams moved to suppress; the magistrate and district court denied the motion, finding the initial mistake reasonable, the stop not impermissibly prolonged, and the inventory search lawful. Williams appealed but the Eighth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer’s mistaken belief that the red Challenger was stolen was objectively reasonable	Williams: the misreading was unreasonable and invalidated the stop	Government: the mistake was objectively reasonable given similar abbreviations, proximity to a known stolen car, high-crime area, and on-the-move circumstances	Court: Mistake was objectively reasonable and supplied reasonable suspicion for the investigatory stop
Whether the investigatory stop was unlawfully prolonged after officers learned vehicle was not stolen	Williams: Stop should have ended when VIN/plate checks showed car not stolen	Government: Short time elapsed (~2 minutes); new suspicious facts (expired tags, evasive answers, no owner identification, observed drugs) justified continued detention	Court: Detention not impermissibly extended; new developments gave reasonable suspicion and led to probable cause for towing/inventory search

United States v. Smith, 820 F.3d 356 (8th Cir.) (standard of review for suppression rulings)
United States v. Hollins, 685 F.3d 703 (8th Cir.) (reasonable suspicion and permissible scope/duration of stops)
United States v. Smart, 393 F.3d 767 (8th Cir.) (objective-reasonableness test for officer mistakes)
United States v. Houston, 548 F.3d 1151 (8th Cir.) (traffic stop as Fourth Amendment seizure)
United States v. Quintero-Felix, 714 F.3d 563 (8th Cir.) (completion of traffic stop purpose and continuation rules)
Arizona v. Johnson, 555 U.S. 323 (2009) (officer inquiries unrelated to stop are permissible if they do not measurably extend duration)
United States v. Watts, 7 F.3d 122 (8th Cir.) (original grounds dissipating does not preclude continued stop based on new reasonable suspicion)