United States v. Morgan, 2017 U.S. App. LEXIS 7744

Around 10:30 p.m. in a high‑crime Tulsa area, Officer Barnhart observed Phillip Morgan riding a bicycle against traffic and without a headlight, violating city law.
Barnhart approached; Morgan made movements toward his pant pockets and kept hands near pockets after being told to keep them out.
Morgan gave a false name and identifiers; database returns showed “no result,” prompting suspicion and a call for backup.
Barnhart twice ordered Morgan to step off the bicycle; Morgan refused and then reached into his left front pants pocket.
Officers grabbed Morgan, forced him to the ground, tasered him when he refused to show his hands, handcuffed him, and found a loaded .38 revolver.
Morgan was indicted for being a felon in possession of a firearm, moved to suppress the gun, district court denied suppression, jury convicted, and the Tenth Circuit affirmed.

Issue	Morgan's Argument	Government's Argument	Held
Whether officer could order a bicyclist to get off his bicycle during a lawful traffic stop	Ordering him off exceeded the stop’s scope because Oklahoma law doesn’t require ID for bicyclists and removing him was unnecessary	Analogous to ordering motorists/passengers out of cars (Mimms/Wilson); stepping off a bike is de minimis and reduces flight risk	Officer permissibly ordered Morgan off the bicycle; reasonable under Fourth Amendment
Whether officer could request identification and run checks after the stop	Because bicyclists need no driver’s license, officer lacked authority to demand ID beyond citation/ warrant check	Determining identity is routine and lawful during a stop; false name prolonged the stop and justified further inquiry	Requesting and checking identification was within the stop’s scope; Morgan’s false info extended the detention
Whether forcing Morgan to the ground and tasering him converted the stop into an arrest without probable cause	Use of force went beyond investigative detention and became an arrest without probable cause	Officers reasonably used force to protect safety after refusal to comply and reaching into pocket; objective standard supports use	Use of force (force to ground and taser to gain compliance/handcuff) was reasonable to protect officer safety and did not require separate probable cause

Whren v. United States, 517 U.S. 806 (Fourth Amendment reasonableness for traffic stops)
Terry v. Ohio, 392 U.S. 1 (investigative detention/stop-and-frisk framework)
Pennsylvania v. Mimms, 434 U.S. 106 (officer may order driver out of lawfully stopped vehicle)
Maryland v. Wilson, 519 U.S. 408 (Mimms extends to passengers)
Hiibel v. Sixth Judicial Dist. Ct. of Nev., 542 U.S. 177 (questions of identity routine in investigations)
United States v. Hood, 774 F.3d 638 (10th Cir. 2014) (safety justification for ordering suspect to ground, handcuffing, and frisking)