United States v. Robinson
2012 U.S. App. LEXIS 4841
| 8th Cir. | 2012Background
- Robinson, a felon, was convicted in a federal case for unlawful firearm possession under 18 U.S.C. §§ 922(g)(1), 924(e) after a bench trial.
- An off-duty security officer notified police Robinson had a gun and returned to the club in a white car.
- Officers followed the car, detained the occupants, and pat-searched them; a weapons warrant check revealed Robinson’s felon status and warrants.
- A handgun was observed sticking out from under the driver's seat during an inventory search of the car.
- Robinson argued the stop lacked reasonable suspicion and that placing him in the patrol car exceeded the investigative stop.
- The district court denied suppression; Robinson was convicted and sentenced to 235 months; on appeal, challenge focused on stop and stop-incursion
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop supported by reasonable suspicion? | Robinson contends no reasonable suspicion. | Police relied on security guard tip corroborated by car description. | Yes, reasonable suspicion supported the stop. |
| Did handcuffing exceed investigative-stop limits? | Claim raised for the first time; plain error. | Handcuffing for safety during stop was permissible. | No plain error; handcuffing within bounds. |
Key Cases Cited
- Adams v. Williams, 407 U.S. 143 (U.S. 1972) (informant tips may support suspicion depending on reliability)
- United States v. Sokolow, 490 U.S. 1 (U.S. 1989) (reasonable suspicion for stop based on totality of circumstances)
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality of circumstances governs reasonable suspicion)
- United States v. Dawdy, 46 F.3d 1427 (8th Cir. 1995) (factors like time and location support stop reasonableness)
- Nesdahl v. State, 890 S.W.2d 598 (Ark. 1995) (informant reliability influences reasonable suspicion)