United States v. Phillips, 2012 U.S. App. LEXIS 11207

October 25, 2010, a shooting occurred in Cedar Rapids; Hollie, a felon, was believed to possess firearms and stay at 1418 4th Ave SE.
Police investigated Hollie and tracked him to a location near 1418; they later identified a suspect similar in description.
On Oct 27, 2010, officers followed a white vehicle with a man believed to be Hollie; no traffic violation justified the stop.
During the stop, the subject reached for his right pocket and appeared to shield himself; identification was requested.
The subject, identified as Tony Phillips via ID, admitted having a pistol in his front pocket; Phillips was detained and later charged with felon in possession of a firearm.
Phillips moved to suppress the evidence arguing the stop and detention violated the Fourth Amendment; the district court denied the motion and Phillips pled guilty with a conditional plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was reasonable under Fourth Amendment based on mistaken identity.	Phillips (Phillips) argues the belief was not objectively reasonable.	Phillips contends the mistaken belief could not justify a stop.	Yes; the mistake was objectively reasonable, so the stop was valid.
Whether ordering Phillips to exit the vehicle was permissible during an investigative stop.	Phillips argues no necessity to exit; ID could be checked from within.	Officer allowed exit for safety; stop ongoing and reasonable.	Yes; exiting was permissible for safety during an ongoing stop.

Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (establishes de novo review of Fourth Amendment determinations; reasonableness of stop depends on objective circumstances)
United States v. Smith, 648 F.3d 654 (8th Cir. 2011) (applies objective reasonableness in mistaken-belief scenarios)
United States v. Robinson, 670 F.3d 874 (8th Cir. 2012) (standard for investigative stops and authority to detain)