United States v. Fonseca, 2014 U.S. App. LEXIS 4382

Defendant burglarized a Missouri gun store with his girlfriend, stealing 36 handguns; they later traveled to Kansas to sell them; eight firearms remained in Defendant’s possession in a bag carried during a nighttime stop.
Officer Reynolds conducted a Terry stop in a high-crime area after Defendant was seen with a bag and acting suspiciously; the bag was later moved and Defendant was questioned for approximately 20 minutes.
Defendant provided inconsistent information about ownership of the bag; Kaylin’s bag was later identified and searched, revealing no illegal contents.
Ms. White lied about the bag’s contents but later admitted the truth; officers obtained Kaylin’s consent to search her bag, revealing eight firearms in a black computer bag in the car.
Defendant was indicted for possessing stolen firearms; after suppression rulings and evidentiary rulings, the jury convicted him and he was sentenced to 70 months; he challenged suppression and the admission of gun-sales testimony.
The district court denied suppression of the eight firearms; the court granted in limine relief regarding gun-sales testimony, which the government later elicited despite the ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonableness of the Terry stop’s scope	Fonseca contends the stop extended beyond reasonable suspicion.	Fonseca argues additional detention after dialogue yielded no incriminating info.	Detention upheld as reasonable in scope.
Admission of gun-sale testimony despite in limine ruling	Fonseca argues the gun-sales testimony violated the pretrial ruling and should reverse.	Government timely elicited gun-sale testimony despite ruling; error if any was plain.	No plain-error; conviction affirmed.

Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (establishes Terry stop framework; reasonable suspicion and scope limits)
United States v. Jones, 523 F.3d 1235 (10th Cir. 2008) (stopping and detention standards; deference to police conduct)
United States v. White, 584 F.3d 935 (10th Cir. 2009) (reasonable-suspicion and scope in detentions)
United States v. Muldrow, 19 F.3d 1332 (10th Cir. 1994) (detention length tied to identification verification; legitimate investigative goals)
United States v. Trimble, 986 F.2d 394 (10th Cir. 1993) (detention tied to determining what’s going on in an investigation)
United States v. Sharpe, 470 U.S. 675 (1985) (reasonableness of investigative detentions; lenient review of police actions)
Mejia-Alarcon, 995 F.2d 982 (10th Cir. 1993) (motion in limine preservation and timing matters; preview of plain error rule application)