United States v. Lofton
3:25-cr-00012
| E.D. Va. | Jun 30, 2025Background
- Rashon Lofton was indicted for possession of a firearm by a convicted felon after being found slumped over in a car at a gas station with another individual.
- Police were called to the scene in response to a 911 report of a possible overdose, with the car parked at a gas pump, engine running, lights on.
- Officer Pardee, with prior knowledge of drug activity at this location, knocked on the vehicle window and quickly opened the door to investigate.
- Upon opening the door, Pardee saw a cut straw with white residue in the center console and asked Lofton to exit; Lofton was handcuffed, and a firearm was discovered in his pocket.
- Lofton moved to suppress evidence, arguing the entry and search were unconstitutional under the Fourth Amendment.
- The United States opposed, relying on reasonable suspicion, the Terry stop doctrine, and inevitable discovery exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer-entry violated 4th Amendment | Entry was unlawful search | Entry justified by emergency/caretaking | Even if entry was unlawful, evidence admissible under inevitable discovery |
| Whether reasonable suspicion existed for Terry stop | No reasonable suspicion prior to entry | Officer had sufficient articulable facts | Officer had reasonable suspicion before entry, justifying a Terry stop |
| Application of inevitable discovery doctrine | Evidence was tainted, must be suppressed | Evidence would have been lawfully found | Evidence would have been inevitably discovered regardless of any Fourth Amendment violation |
| Legality of the search and seizure of firearm | Search and seizure were not justified | Search justified under exceptions | Search lawful as evidence would inevitably be discovered through valid Terry stop |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for brief investigatory detentions or Terry stops when reasonable suspicion exists)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (clarifies reasonable suspicion standard under Terry)
- United States v. Sokolow, 490 U.S. 1 (1989) (reiterates reasonable suspicion is less than probable cause and based on totality of the circumstances)
- United States v. Arvizu, 534 U.S. 266 (2002) (emphasizes looking at totality of circumstances for reasonable suspicion determination)