United States v. Glover, 662 F.3d 694

Glover, a felon, pleaded guilty conditionally to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).
In the early morning hours, two CMPD officers patrolled a high-crime Eastway Division area known for robberies and assaults.
They observed a lone gas-station attendant outside the locked building while Glover stood nearby, watching the attendant.
Glover moved toward the attendant while the officer observed him, leading the officers to approach and frisk him.
The officers conducted a stop-and-frisk based on observed suspicious conduct; a handgun was recovered from Glover’s pocket.
Glover moved to suppress the evidence, arguing the stop lacked reasonable suspicion; the district court denied suppression.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop-and-frisk violated the Fourth Amendment.	Glover argues no reasonable suspicion existed.	Skipper/Archer argue totality of circumstances supported suspicion.	Stop-and-frisk supported by reasonable suspicion; affirmed.

Terry v. Ohio, 392 U.S. 1 (1968) (protective stop permissible when armed and dangerous suspected)
United States v. Cortez, 449 U.S. 411 (1981) (totality of circumstances governs stop-based on suspicion)
United States v. Wardlow, 528 U.S. 119 (2000) (lateness and isolation heighten suspicion)
United States v. Arvizu, 534 U.S. 266 (2002) (multifactor analysis supports reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (truth of suspicion evaluated by totality of circumstances)
United States v. Perkins, 363 F.3d 317 (4th Cir. 2004) (protective stops may be based on suspicious activity)
United States v. Foster, 634 F.3d 243 (4th Cir. 2011) (context-specific limits on stop-based on suspicion)
Adams v. Williams, 407 U.S. 143 (1972) (brief stop when reasonably suspicious of danger)
Michigan v. Long, 463 U.S. 1032 (1983) (police may conduct protective searches for safety)