United States v. Eric Davison, 808 F.3d 325

Officer Pickens, investigating a reported stolen pickup, observed two individuals (Davison and Hall) who matched a limited description given by store owners and who had been seen near the stolen truck.
Pickens conducted surveillance, drove around the block multiple times, and observed the pair repeatedly glance at police and alter course; they walked through the yard of a residence Pickens knew as a drug house.
Believing they matched the stolen-vehicle suspects and posed a safety risk in a high-crime area with recent shootings, Pickens stopped and immediately frisked both individuals.
During a frisk of Davison, Pickens felt an object consistent with a firearm; Davison admitted his felony status and was arrested. A subsequent search revealed a loaded .22 revolver, ammunition, methamphetamine, and a syringe.
Davison moved to suppress the firearm and other evidence, arguing the stop and frisk violated the Fourth Amendment for lack of reasonable suspicion. The district court denied suppression; Davison appealed.
The Eighth Circuit affirmed, concluding the totality of the circumstances supplied reasonable suspicion for both the Terry stop and the protective frisk.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to make an investigative Terry stop	Davison: walking on public sidewalk with companion is innocuous; no reasonable suspicion to detain	Pickens: suspects matched stolen-vehicle description, evaded police, circled near stolen truck and went through known drug house in high-crime area	Held: Stop was supported by reasonable suspicion under the totality of the circumstances
Whether officer had reasonable, articulable suspicion to frisk for weapons	Davison: frisk was unjustified and therefore evidence should be suppressed	Pickens: recent shootings, high-crime area, suspects’ evasive behavior, and suspicion of vehicle theft warranted officer safety frisk	Held: Frisk justified—officer reasonably suspected Davison might be armed and dangerous

Terry v. Ohio, 392 U.S. 1 (Terry stop and protective frisk standards)
Ornelas v. United States, 517 U.S. 690 (de novo review of reasonable-suspicion determinations with due weight to officer inferences)
United States v. Arvizu, 534 U.S. 266 (totality-of-the-circumstances analysis for reasonable suspicion)
United States v. Hanlon, 401 F.3d 926 (officers may suspect car thieves might possess weapons)
United States v. Rowland, 341 F.3d 774 (context for suspicion that vehicle-related suspects may be armed)
United States v. Roggeman, 279 F.3d 573 (frisk justified only by reasonable, articulable suspicion that subject is armed)