United States v. Jason Buzzard
1 F.4th 198
| 4th Cir. | 2021Background
- Shortly after 1:30 a.m. on Oct. 12, 2018, Officer Tyler Dawson stopped a car for a defective brake light; Jason Buzzard was the driver and Paul Martin was the passenger.
- Dawson recognized Martin (prior contacts; known felon with drug history) and observed Martin acting nervously and moving around in the passenger seat.
- While awaiting backup, Dawson asked whether there was anything illegal in the vehicle; Buzzard produced a marijuana bowl and Martin produced a syringe.
- Additional officers arrived, occupants were removed, and a search recovered two handguns wrapped in socks under the driver’s and passenger’s seats.
- District court denied motions to suppress; Buzzard pleaded guilty (preserving suppression appeal); Martin was tried, convicted of felon-in-possession, had supervised-release revoked, and appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dawson’s question (“Is there anything illegal in the car?”) exceeded the traffic-stop mission under the Fourth Amendment | Question was unrelated to traffic enforcement and transformed the stop into a criminal investigation (Rodriguez) | Question was reasonably related to officer and highway safety given time, location, Martin’s history and behavior | Court held the question related to officer safety and thus fell within the stop’s mission |
| Whether the question unlawfully prolonged the stop in violation of Rodriguez | Question impermissibly extended the stop to investigate unrelated criminal activity | Question was asked while the stop was ongoing (officer still awaiting backup and had not completed document checks), so it did not extend the stop | Court held the question did not prolong the stop; suppression denial affirmed |
| Sufficiency of the evidence for Martin’s felon-in-possession conviction | Martin argued the government failed to prove he possessed the recovered guns | Government pointed to Facebook messages arranging the sale, surveillance of Martin entering the car, Buzzard’s testimony that he handed the guns to Martin, Martin’s movements in the car, and statements about guns | Court held the evidence was sufficient for a reasonable jury to find possession beyond a reasonable doubt; acquittal denied |
| Revocation of Martin’s supervised release | Martin argued revocation depended on an unsupported conviction | Government relied on the sustained conviction and supporting evidence | Court affirmed revocation because the conviction was supported and affirmed |
Key Cases Cited
- Rodriguez v. United States, 575 U.S. 348 (2015) (traffic-stop "mission" limits permissible inquiries and extensions)
- Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during a lawful traffic stop does not violate the Fourth Amendment)
- Arizona v. Johnson, 555 U.S. 323 (2009) (officer safety justifies certain passenger-related inquiries and precautions)
- United States v. Bowman, 884 F.3d 200 (4th Cir. 2018) (officers may ask unrelated questions during a stop so long as they do not prolong it)
- United States v. Martin, 395 F. Supp. 3d 756 (S.D.W. Va. 2019) (district-court analysis finding question related to officer safety)
- United States v. Everett, 601 F.3d 484 (6th Cir. 2010) (recognizing officers’ authority to inquire about weapons during traffic stops)