United States v. Paris Yancey
928 F.3d 627
7th Cir.2019Background
- At ~1:48–1:58 a.m., Rock Island officers stopped a car for the driver McCorkle’s outstanding arrest warrant; Paris Yancey was the front-seat passenger.
- Officers recognized Yancey from prior confrontations and a department contact sheet warning he may be armed; they therefore planned a protective pat‑down.
- McCorkle was handcuffed and placed in an officer’s squad car; officers were still inventorying her purse and deciding who could legally drive the car.
- While officers were finishing these tasks and after repeatedly telling Yancey to wait, Yancey exited the vehicle and ran; officers tackled him and observed a handgun in his waistband.
- Yancey was charged with felon-in-possession, moved to suppress the gun (arguing the seizure and pat‑down lacked Fourth Amendment justification), pleaded guilty reserving the suppression appeal, and was sentenced to 71 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers unlawfully continued to detain Yancey after driver was in squad car | Yancey: detention became unreasonable once McCorkle was secured, so officers lacked justification to keep Yancey on scene | Government: the stop was still ongoing because officers were completing tasks related to the arrest (inventory search, disposition of car) | Stop remained lawful while those tasks continued; officers could detain passenger, so detention was lawful |
| Whether pat‑down required reasonable suspicion before it occurred | Yancey: officers lacked reasonable suspicion to frisk him | Government: officers had reasons (history, contact sheet, nervousness) to suspect danger | Not reached on appeal because no pat‑down occurred before Yancey fled; seizure justified by ongoing stop |
Key Cases Cited
- Arizona v. Johnson, 555 U.S. 323 (requiring reasonable suspicion a passenger is armed and dangerous before a frisk when a pat‑down occurs)
- Navarette v. California, 572 U.S. 393 (traffic stop reasonable where officer has particularized suspicion)
- United States v. Cortez, 449 U.S. 411 (standards for particularized, objective suspicion)
- Maryland v. Wilson, 519 U.S. 408 (officers may order passengers out of vehicle during a traffic stop)
- Rodriguez v. United States, 575 U.S. 348 (traffic stop permissible only for time to complete its mission; unrelated inquiries cannot measurably extend duration)
- Illinois v. Caballes, 543 U.S. 405 (scope of traffic stop tied to its mission)
- Florida v. Royer, 460 U.S. 491 (detention scope must be tailored to underlying justification)
- United States v. Richmond, 924 F.3d 404 (7th Cir. 2019) (standard of review: factual findings for clear error; legal conclusions de novo)
- United States v. Cartwright, 630 F.3d 610 (7th Cir. 2010) (inventory searches incident to arrest permitted when following routine procedures)