United States v. Ramone R. Bright, 709 F. App'x 576

In Jan. 2015 a postal inspector flagged a parcel addressed to “John Bright” from “SJ Clothing” as suspicious during routine inspection.
Inspector noted multiple red flags: handwritten label on a business-style package, heavy taping, origin from Los Angeles (known narcotics source), waiver of signature requirement, and sender/recipient not associated with the listed addresses.
A certified narcotics detection dog alerted to the package; police obtained a warrant to open it and found a brick of cocaine.
Police then obtained an anticipatory search warrant for the residence the package was addressed to; after the parcel was delivered and signed for by Bright’s codefendant, officers searched the home and found multiple drugs, drug paraphernalia, scales, and two handguns.
Bright moved to suppress evidence; the district court denied the motion. Bright pleaded guilty to drug and felon-in-possession charges, reserved the suppression issue on appeal, and was sentenced to 57 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the postal inspector had reasonable suspicion to detain the package for K-9 inspection	Bright: the inspector lacked specific, articulable facts amounting to reasonable suspicion — detention violated Fourth Amendment	Government: combined indicators (handwritten label, heavy tape, origin city, waived signature, unassociated sender/recipient) gave particularized, objective basis to detain until canine inspection	Court: Affirmed — totality of circumstances supported reasonable suspicion to detain package until canine established probable cause

United States v. Banks, 3 F.3d 399 (11th Cir. 1993) (upholding temporary detention of suspicious mail pending canine inspection)
Illinois v. Wardlow, 528 U.S. 119 (2000) (reasonable suspicion is less than probable cause)
Terry v. Ohio, 392 U.S. 1 (1968) (reasonable-suspicion standard requires specific, articulable facts)
Ornelas v. United States, 517 U.S. 690 (1996) (review standard: factual findings for clear error; legal application de novo; give due weight to officers’ inferences)
United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-circumstances test for reasonable suspicion)
United States v. Perkins, 348 F.3d 965 (11th Cir. 2003) (officer must have more than a hunch)
United States v. Van Leeuwen, 397 U.S. 249 (1970) (fictitious or unassociated addresses can support reasonable suspicion)
United States v. Barber, 777 F.3d 1303 (11th Cir. 2015) (standard of review for mixed questions of fact and law)