United States v. Fuller, 120 F. Supp. 3d 669

On Oct. 11, 2014 two Washtenaw County deputies stopped Antonio Fuller while looking for Gerald Warlix, a suspect with an outstanding warrant; one deputy mistakenly believed Fuller might be Warlix.
Fuller told deputies he was not Warlix and produced ID confirming his identity; both deputies concluded he was Fuller, not Warlix.
After confirming Fuller’s identity, Deputy Montgomery nevertheless decided to continue detaining Fuller to run a warrant check despite having no affirmative belief a warrant existed.
While one deputy ran the warrant check, Deputy Montgomery attempted a pat‑down; Fuller declined consent, broke free, and fled on foot.
Deputies chased, tackled, handcuffed Fuller, then found a loaded handgun in his pocket; Fuller, a convicted felon, was charged under 18 U.S.C. § 922(g)(1).
The court held the initial stop (to identify Warlix) was supported by reasonable suspicion, but the continued detention after ID dispelled that suspicion was unlawful; evidence obtained after the unlawful detention was suppressed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Fuller was seized when deputies began questioning him	Fuller was seized because deputies’ words/tone conveyed he was required to engage	Government: the encounter was consensual, not a seizure	Court: seizure occurred — reasonable person would not feel free to leave
Whether initial seizure was lawful	Fuller: initial stop exceeded permissible scope	Government: stop was justified because deputies reasonably suspected Fuller was Warlix	Court: initial stop lawful — reasonable suspicion to investigate identity of Warlix
Whether continuing detention to run a warrant check was lawful after ID showed Fuller was not Warlix	Fuller: detention unlawfully continued after reasonable suspicion was dispelled	Government: deputy had reasonable suspicion or at least arguable basis to believe a warrant might exist	Court: unlawful — suspicion was dispelled by ID and deputy’s speculation about a warrant was mere hunch
Admissibility of gun found after Fuller fled	Fuller: gun is fruit of illegal detention; flight did not purge taint	Government: flight created probable cause to arrest for resisting/obstructing, so discovery was independent	Court: excluded evidence — flight from an unlawful detention did not create probable cause; no attenuation of the taint

Terry v. Ohio, 392 U.S. 1 (establishes standard for investigatory stops and frisks)
Mendenhall v. United States, 446 U.S. 544 (seizure test: would a reasonable person feel free to leave)
Florida v. Bostick, 501 U.S. 429 (totality of circumstances governs whether encounter is a seizure)
Arizona v. Johnson, 555 U.S. 323 (Terry stop principles applied to passenger questioning)
United States v. McSwain, 29 F.3d 558 (officer may not continue detention to check records after suspicion evaporates)
United States v. Edgerton, 438 F.3d 1043 (detention must end without undue delay once suspicion is dispelled)
United States v. Davis, 430 F.3d 345 (continued detention after suspicion dispelled violates Fourth Amendment)
United States v. Lyons, 510 F.3d 1225 (warrant checks permissible if original reasonable suspicion remains intact)
United States v. Williams, 615 F.3d 657 (speculation about outstanding warrants based on prior arrests is inadequate for reasonable suspicion)
Wong Sun v. United States, 371 U.S. 471 (fruit of the poisonous tree and attenuation doctrine)
Brown v. Illinois, 422 U.S. 590 (factors for attenuation: time, intervening circumstances, flagrancy)
Herring v. United States, 555 U.S. 135 (exclusionary rule not warranted for isolated negligence; suppression when misconduct is deliberate/reckless)
United States v. Brodie, 742 F.3d 1058 (foot flight from unlawful stop did not attenuate taint where flight was not a new, distinct crime)