United States v. Jan Edmonds, 606 F. App'x 656

On Jan. 15, 2012, Pittsburgh officers observed Jan Michael Edmonds drive erratically (crossing lanes, parking the wrong way) and initiated a traffic stop.
Edmonds exited his Jeep and fled on foot; officers pursued, tackled, and used force (one punch; baton strikes) when he resisted and refused to show his hands.
During a pat-down after subdual, officers observed a large bulge in Edmonds’s rear waistband and recovered a loaded .40 Glock and an extra magazine; database checks showed the gun was reported stolen and Edmonds had prior felony convictions and a suspended license.
Edmonds was charged in state court and later indicted federally for being a felon in possession (18 U.S.C. § 922(g)(1)) and possession of a stolen firearm (18 U.S.C. § 922(j)); he moved to suppress the firearm and ammunition.
The District Court denied suppression and designated Edmonds an Armed Career Criminal under the ACCA based on six prior Pennsylvania convictions for possession with intent to deliver; Edmonds pleaded guilty conditionally and appealed the suppression ruling and ACCA designation.

Issue	Edmonds’s Argument	Government’s Argument	Held
Whether the initial traffic stop was lawful	Stop was invalid and therefore subsequent seizure/search unlawful	Officers observed traffic violations giving reasonable suspicion to stop	Stop was lawful; officers had reasonable suspicion to stop vehicle
Whether pursuit, tackling, and force were excessive	Use of force (punch, baton strikes) rendered seizure unlawful and tainted the search	Force was reasonable to effectuate stop and subdue flight/resistance	Force was reasonable under circumstances; seizure valid
Whether pat-down/search producing gun violated Fourth Amendment	Search was unlawful because of prior excessive force and lack of justification	Pat-down justified by reasonable suspicion that Edmonds was armed and dangerous	Pat-down was lawful; bulge and flight provided reasonable suspicion and pat-down revealed weapon
Whether Edmonds’s prior PA drug convictions qualify as ACCA "serious drug offenses"	Argues convictions do not qualify for ACCA enhancement	Abbott controls and supports treating those convictions as predicate offenses	Court bound by United States v. Abbott; prior convictions qualify and ACCA enhancement applies

United States v. Bonner, 363 F.3d 213 (3d Cir.) (flight from a lawful traffic stop can justify further stop and pursuit)
Pennsylvania v. Mimms, 434 U.S. 106 (1977) (officer may stop vehicle for traffic violation)
Graham v. Connor, 490 U.S. 386 (1989) (use-of-force reasonableness standard)
United States v. Navedo, 694 F.3d 463 (3d Cir.) (Terry pat-down justified where officer reasonably suspects suspect is armed and dangerous)
United States v. Abbott, 748 F.3d 154 (3d Cir.) (treats certain Pennsylvania drug-possession-with-intent offenses as ACCA predicate "serious drug offenses")
Hudson v. Michigan, 547 U.S. 586 (2006) (exclusionary rule requires a causal connection between constitutional violation and discovery of evidence)