United States v. Reginald Lloyd, 581 F. App'x 203

Lloyd was convicted of Hobbs Act robbery, 18 U.S.C. § 1951; use of a firearm during a crime of violence, § 924(c); and felon in possession, § 922(g).
Police relied on a radio broadcast describing two armed suspects and a vehicle; they observed a matching vehicle after the broadcast.
A high-speed chase followed when the vehicle fled; it eventually stopped after the driver crashed at a gas station.
Officers could not see into the fogged car; Lloyd remained in the driver’s seat and was physically removed and arrested after failing to exit on command.
Lloyd answered questions about the gun location and the second suspect before Miranda warnings; he stated, “It’s in the back” and “He got out.”
The district court denied Lloyd’s suppression motion; the Fourth Circuit reviews de novo and defers to credibility findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statements made pre-Miranda were admissible	Lloyd argues statements were improper under Miranda and not within Quarles safety exception	The government contends the public safety exception justified admission due to weapon risk	Admissible under public safety exception

Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (required warnings before custodial interrogation absent exception)
New York v. Quarles, 467 U.S. 649 (U.S. 1984) (public safety exception to Miranda)
United States v. McGee, 736 F.3d 263 (4th Cir. 2013) (standard of review for suppression rulings)
United States v. Black, 707 F.3d 531 (4th Cir. 2013) (evidence reviewed in light most favorable to Government)
United States v. Griffin, 589 F.3d 148 (4th Cir. 2009) (credibility determinations in suppression rulings)