United States v. Jones, 678 F.3d 293

Two uniformed, armed officers followed Jones from a public street onto private property, then blocked his car’s exit in a one-way driveway.
The officers did not observe any traffic violation or other legitimate reason to stop Jones prior to the shirt lift and pat-down.
Jones and a companion voluntarily lifted their shirts and submitted to a pat-down; no weapons were found, and Jones later admitted his license was revoked.
Subsequently, a handgun and marijuana were found; Jones was charged with possession of a firearm by an unlawful user of controlled substances.
The district court denied suppression, treating the shirt lift/pat-down as consensual until a traffic violation gave rise to detention; Jones timely appealed.
The Fourth Circuit held that the initial interaction was a seizure, reversed, and remanded for suppression of the gun and marijuana.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the officers' conduct constitute a seizure before any traffic violation?	Jones argues the encounter was non-consensual.	Aeschlimann asserts it was a consensual encounter until a ticketable violation arose.	Yes; the initial encounter was a seizure.
Did the officers block the vehicle and follow onto private property to speak with Jones, signaling a detention?	Jones contends blocking and following signaled coercive detention.	The Government argues it remained consensual until a later detention based on a traffic violation.	Yes; blocking and pursuing Jones supported a detention.
Did the requests to lift his shirt and to submit to a pat-down amount to intrusive conduct during a non-consensual seizure?	Jones maintains these requests were coercive and not part of a routine encounter.	The Government contends they were merely routine safety checks within a consensual encounter.	Yes; the requests contributed to a seizure and violated the Fourth Amendment.
Should the seized evidence be suppressed as fruit of an unlawful seizure?	Unlawful seizure tainted the gun and marijuana evidence.	Evidence should be admitted if the encounter was consensual or permissible under exception.	Yes; the evidence was suppressed.

Florida v. Bostick, 501 U.S. 429 (1991) (standard for when encounters with police on buses are seizures)
Terry v. Ohio, 392 U.S. 1 (1968) (foundational framework for detentions and seizures based on reasonable suspicion)
United States v. Mendenhall, 446 U.S. 544 (1980) (reasonable person standard for whether an encounter is a seizure)
United States v. Drayton, 536 U.S. 194 (2002) (bus interdiction context; no per se seizure rule there)
United States v. Gray, 883 F.2d 320 (4th Cir. 1989) (totality of circumstances in assessing whether a seizure occurred)
United States v. Weaver, 282 F.3d 302 (4th Cir. 2002) (de novo review of whether police detention occurred)
United States v. Lattimore, 87 F.3d 647 (4th Cir. 1996) (en banc discussion on determining voluntary consent and seizures)