United States v. Forest Norville, 43 F.4th 680

At ~1:00 a.m. in Galesburg, IL, police stopped Forest Norville on a motorized bicycle after an officer who knew him learned his driver’s license was revoked; officer arrested him under an Illinois statute treating the bicycle as a motor vehicle requiring a license.
During a search incident to arrest officers found prescription pills, a digital scale, and ~120 grams of methamphetamine.
Norville was charged federally with possession with intent to distribute ≥50 grams of methamphetamine and moved to suppress the drugs, arguing police lacked probable cause for the arrest and requesting an evidentiary hearing.
The government relied on a police dashboard camera video that the parties stipulated was admissible and that showed Norville at a stop sign; Norville initially conceded a roll-through but later argued the video showed a brief stop and that an evidentiary hearing was needed to determine the legally required stop point (no stop lines at the intersection).
The district court denied suppression and an evidentiary hearing, finding the video showed Norville never came to a complete stop; the court also applied the objective probable-cause standard (officer’s subjective reason for arrest need not control). A jury convicted Norville and he appealed only the denial of the suppression hearing.
The Seventh Circuit reviewed the video, agreed Norville did not fully stop, concluded a rolling stop provided probable cause, and affirmed the denial of an evidentiary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred by denying an evidentiary hearing on Norville's motion to suppress	Norville: video ambiguous; needed hearing to resolve whether he truly stopped and where he was required to stop (no stop lines) and whether bicycle qualified as motor vehicle	Government: video shows at least a rolling stop that supplied probable cause; no disputed material fact; hearing unnecessary	Denied — district court did not abuse discretion; video dispelled material factual dispute and established probable cause
Whether probable cause existed based on the stop-sign conduct	Norville: contest video’s clarity; if he stopped, no probable cause from stop-sign violation	Government: a rolling stop is sufficient to create probable cause; officer need not cite the exact offense he relied on	Held that a rolling stop provided probable cause; Norville conceded that a rolling stop would suffice, so analysis ends

Ramos v. City of Chicago, 716 F.3d 1013 (7th Cir. 2013) (probable-cause inquiry is objective; the offense for which probable cause exists need not match the officer’s subjective stated offense)
United States v. Edgeworth, 889 F.3d 350 (7th Cir. 2018) (district courts may forgo evidentiary hearings on suppression motions when no disputed material facts remain)
United States v. Curlin, 638 F.3d 562 (7th Cir. 2011) (same discretionary standard for suppression hearing necessity)
Scott v. Harris, 550 U.S. 372 (U.S. 2007) (courts may view facts in the light depicted by videotape; video evidence can resolve factual disputes)
United States v. Johnson, 874 F.3d 571 (7th Cir. 2017) (a rolling stop can independently support probable cause for arrest)