United States v. Goebel, 959 F.3d 1259

Late night (≈2:45–3:30 a.m.), Officer Barleen observed Goebel’s car make an abrupt/evasive turn; he followed and the car pulled into a driveway in a high‑crime neighborhood.
Goebel exited, walked to the backyard without approaching the front door; officer stopped briefly to get the plate, then parked away from the driveway and activated his body camera.
A front‑seat passenger approached the officer and could not identify the residence; a rear passenger said she didn’t know Goebel or the house occupants.
The homeowner denied knowing the occupants or a person named “Joseph,” consented to searches of a van and the backyard; Barleen then handcuffed and detained Goebel for suspicious activity/trespass/possible vehicle burglary.
Officer Barleen searched and found a handgun in the alley about 17 minutes after the detention; Goebel was later Mirandized twice, waived, denied ownership, and was charged under 18 U.S.C. § 922(g)(1). He pleaded guilty while reserving the right to appeal the suppression ruling.
The district court denied the suppression motion except for suppressing a few statements from a one‑minute period when Goebel was handcuffed but not Mirandized; the government appealed denial as to the gun and other statements.

Issue	Goebel's Argument	Government's Argument	Held
Standard of review for disputed suppression evidence	District court applied wrong standard (should not view evidence favorably to government)	Any error waived by failure to object; no plain error	Waived; even under plain‑error no prejudice shown, so no relief
Whether detention (when ordered off car) lacked reasonable suspicion	Detention began when officer momentarily blocked driveway and that lacked reasonable suspicion	Detention occurred later after officer ordered Goebel off the car, by which time specific facts gave reasonable suspicion	No Fourth Amendment violation—reasonable suspicion supported detention at point of seizure
Whether the Terry stop was unreasonably prolonged	Officer’s investigation lasted too long (17 minutes until gun found)	Officer diligently pursued means to confirm/dispel suspicions (questioning occupants, contacting dispatch, homeowner, and searching van/backyard)	Not unreasonably prolonged; 17 minutes and investigative steps were reasonable
Whether Goebel’s statements required Miranda or were involuntary waivers	Initial sidewalk interaction was custodial; statements should be suppressed	Sidewalk encounter was noncustodial; subsequent waivers were knowing and voluntary	Sidewalk statements admissible (except those already suppressed); later Mirandized statements valid and voluntary

Florida v. Bostick, 501 U.S. 429 (1991) (objective test for seizure—would reasonable person feel free to leave)
Terry v. Ohio, 392 U.S. 1 (1968) (officer may detain based on reasonable suspicion of criminal activity)
United States v. Arvizu, 534 U.S. 266 (2002) (totality of circumstances governs reasonable‑suspicion analysis)
Illinois v. Wardlow, 528 U.S. 119 (2000) (presence in high‑crime area can contribute to reasonable suspicion)
Rodriguez v. United States, 575 U.S. 348 (2015) (Terry stop may not be prolonged beyond time to handle mission of stop)
United States v. Sharpe, 470 U.S. 675 (1985) (assess whether police diligently pursued investigation during detention)
United States v. McHugh, 639 F.3d 1250 (10th Cir. 2011) (seizure occurs when officer shows authority and person submits)
United States v. Chavira, 467 F.3d 1286 (10th Cir. 2006) (suppression requires causal link between violation and evidence)
United States v. Cone, 868 F.3d 1150 (10th Cir. 2017) (must show unlawful act was but‑for cause of discovery)
United States v. Leffler, 942 F.3d 1192 (10th Cir. 2019) (failure to preserve issue and not raise plain‑error forfeits review)
United States v. Smith, 606 F.3d 1270 (10th Cir. 2010) (factors for voluntariness of Miranda waivers)