United States v. Devon Coleman, 18 F.4th 131

On Sept. 20, 2017, a school administrator reported an unknown adult parked erratically and “asleep or passed out” in a car on Patrick Henry High School campus; a crossbow was visible in the backseat.
Deputy David Johnson, a school resource officer, arrived, and the administrator identified the Pontiac Sunfire; the running vehicle was parked primarily in a travel lane with brake lights on.
When Johnson opened his cruiser door, Coleman began to drive away; Johnson activated emergency lights and stopped him. Johnson observed a crossbow butt behind Coleman and that Coleman appeared lethargic.
Coleman told the deputy there was a firearm in the center console; upon exiting the vehicle deputies observed marijuana and then searched the car, finding methamphetamine, baggies, a scale, a .38 revolver, and the crossbow; Coleman was arrested.
Coleman was indicted on federal drug and firearms counts; he moved to suppress the evidence arguing the stop lacked reasonable suspicion because crossbow possession on school grounds is not illegal under Virginia law.
The district court denied suppression; a jury convicted Coleman on all counts and he appealed. The Fourth Circuit affirmed, holding reasonable suspicion existed even without the crossbow and, alternatively, that the crossbow (and any reasonable mistake about its legality) supported the stop.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the deputy had reasonable suspicion to conduct an investigative stop	Coleman: no reasonable suspicion because possession of a crossbow on school property is not illegal; stop therefore unlawful	Government: totality of circumstances (crossbow, erratic parking, sleeping non-student on campus, driver’s evasive driving) gave reasonable suspicion; also other possible crimes (trespass, parking violation, DUI) supported stop	Affirmed: stop was supported by reasonable suspicion even excluding the crossbow; alternatively, treating the crossbow as suspicious also sufficed
Whether the officer’s belief that crossbow possession violated state law was a reasonable mistake of law (Heien)	Coleman: officer’s legal mistake was unreasonable and cannot support reasonable suspicion	Government: statute’s phrase “weapon of like kind” is ambiguous; reasonable minds could differ, so mistake was reasonable under Heien	Court did not need to resolve definitively but held that, even assuming the crossbow was not prohibited, the officer’s mistake would have been reasonable and in any event the stop was valid on other grounds

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (articulable-facts standard for investigative stops)
Heien v. North Carolina, 574 U.S. 54 (U.S. 2014) (an objectively reasonable mistake of law can support reasonable suspicion)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (location and context can heighten suspicion)
Arizona v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality-of-circumstances test for reasonable suspicion)
United States v. Montieth, 662 F.3d 660 (4th Cir. 2011) (officer may stop when reasonable, articulable suspicion of criminal activity exists)