United States v. Patterson
3:24-cr-00179
D.S.C.May 27, 2025Background
- Police were dispatched to a Columbia, SC hotel to assist Yashawnus Leekean Patterson in retrieving his belongings after his reservation was canceled.
- Hotel staff requested that Patterson be placed on trespass notice after he collected his items and went outside.
- Police officers asked Patterson for identification, which he voluntarily provided, while he arranged his own transportation.
- A warrant check revealed Patterson had an outstanding bench warrant for failing to appear in court.
- After confirming the warrant, officers arrested Patterson and, during a search incident to arrest, found a pistol and extended magazine; Patterson admitted he could not legally possess a firearm.
- Patterson was charged as a felon in possession of a firearm and subsequently moved to suppress the seized evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether initial stop was a seizure | Consensual but invalid due to officer's actions | Encounter was consensual | Encounter was consensual |
| Validity of ID/warrant check | Officer lacked reasonable suspicion | Reasonable suspicion not required for consensual encounters | Not required in consensual encounter |
| Legality of detention after warrant found | Detention was unlawful | Detention justified by discovery of warrant | Lawful as based on valid warrant |
| Legality of search incident to arrest | Evidence from search should be suppressed | Lawful search incident to a valid arrest | Search and seizure were lawful |
Key Cases Cited
- United States v. Matlock, 415 U.S. 164 (burden of proof for suppression hearings is preponderance of evidence)
- Florida v. Bostick, 501 U.S. 429 (encounter is consensual unless a reasonable person would not feel free to leave)
- California v. Hodari D., 499 U.S. 621 (defines "seizure" under Fourth Amendment)
- United States v. Weaver, 282 F.3d 302 (consensual police encounters and warrant checks do not implicate Fourth Amendment)
- Brendlin v. California, 551 U.S. 249 (evidence must be suppressed if seized as result of illegal stop)
- Utah v. Strieff, 579 U.S. 232 (search incident to arrest is lawful after discovery of valid warrant)