United States v. Javon Shackleford, 830 F.3d 751

Police received reports that "Javon" (later identified as Javon N. Shackleford) driving a red Monte Carlo might be coming to "shoot up" a nearby residence after assaulting the victim the previous day.
Victim Kimberly Farley reported she had seen Shackleford with a firearm weeks earlier; Farley’s sister relayed similar, contemporaneous information to officers in the area.
Officers King and Edwards located and lawfully stopped the red Monte Carlo, identified Shackleford as the driver, frisked him (no weapon found), handcuffed and seated him, and then arrested him after the victim indicated she wished to prosecute.
Shackleford, a convicted felon, refused consent to search the vehicle. Quentin Fantroy and a woman (Samantha) arrived and requested release of the car; officers refused.
Officer King decided to tow the vehicle and performed an on‑scene inventory search, finding a loaded handgun in the glove compartment.
Shackleford conditionally pleaded guilty to disposing a firearm to a felon under 18 U.S.C. § 922(d)(1), reserving the right to appeal the denial of his suppression motion; the district court denied suppression and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless search of the vehicle was justified under the automobile exception	Shackleford: informant evidence (Farley’s sister) was anonymous and unreliable; no probable cause that a firearm was in the car	Government: combined, consistent reports from victim and her sister plus officers’ observations and defendant’s felon status created probable cause	Court: Held the officers had probable cause under the automobile exception; search was constitutional
Whether the search was a lawful inventory search authorizing seizure	Shackleford: officer’s inventory claim was pretextual and not a valid inventory search	Government: officer conducted an inventory before towing to protect property/safety	Court: Declined to resolve the inventory issue because automobile exception sufficed to affirm denial of suppression

Arizona v. Gant, 556 U.S. 332 (2009) (limits on search‑incident‑to‑arrest doctrine and distinction from automobile exception)
United States v. Ross, 456 U.S. 798 (1982) (automobile exception allows warrantless vehicle searches given probable cause)
United States v. Donnelly, 475 F.3d 946 (8th Cir. 2007) (definition of probable cause as fair probability of finding contraband or evidence)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause standard and informant corroboration analysis)
United States v. Wells, 347 F.3d 280 (8th Cir. 2003) (collective knowledge doctrine for probable cause)
United States v. Olson, 262 F.3d 795 (8th Cir. 2001) (informant reliability and corroboration supporting probable cause)
United States v. Arrocha, 713 F.3d 1159 (8th Cir. 2013) (standard of review and inventory‑search discussion)
United States v. Davis, 569 F.3d 813 (8th Cir. 2009) (automobile‑exception precedent cited)