United States v. Scott, 404 F.Supp.3d 1095

On Jan. 2, 2019, DEA Agent Muse surveilled the Ye Olde Dutch Inn by pole camera; agents believed the location was a drug‑trafficking area.
Muse observed Justin Scott enter the passenger side of a maroon vehicle driven by Derick Ziegler for about two minutes, then return to a silver sedan and leave the lot.
Agents (Rice and detectives) followed the silver sedan into a parking lot, ordered occupants out, and Scott refused consent to search the car.
Within 5–10 minutes of arrival, Agent Rice conducted a pat‑down of Scott and found a handgun; Officer Pollitt then searched Scott and located a pill bottle with controlled substances.
The court reviewed the full surveillance video and found material inconsistencies with Agent Muse’s testimony (e.g., fewer quick passenger exchanges than testified; Scott had entered the Inn multiple times); the court concluded officers lacked reasonable suspicion and probable cause, suppressed the seized evidence, and granted Scott’s motion to suppress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had reasonable suspicion to detain Scott under Terry v. Ohio	The government contended that (1) the Inn was a known drug area, (2) Scott’s brief passenger contact with a suspected drug offender (Ziegler), and (3) the vehicle’s evasive maneuvers created reasonable suspicion	Scott argued that observers saw no exchange, surveillance was inconclusive, and the short contact plus ordinary driving maneuvers do not support reasonable suspicion	No reasonable suspicion; stop unconstitutional and unjustified under Terry
Whether officers had probable cause to arrest Scott and search him incident to arrest	The government relied on the discovery context and officer inferences from surveillance and encounter to support arrest/search	Scott argued there was no probable cause because there was no observed illegal act or reliable corroboration supporting an arrest	No probable cause to arrest; search incident to arrest invalid
Whether suppression of seized evidence is required despite constitutional violation	Government argued officers acted on training/experience and any error was not so culpable to warrant exclusion	Scott argued the unlawful stop and search were the but‑for cause of discovering the gun and drugs and suppression was required to deter misconduct	Exclusionary rule applies; evidence suppressed because misconduct was more than isolated negligence and suppression would deter future violations

Terry v. Ohio, 392 U.S. 1 (1968) (establishes constitutionality of brief investigative stops based on reasonable suspicion)
Chimel v. California, 395 U.S. 752 (1969) (limits search incident to arrest to the arrestee and area within immediate control)
Herring v. United States, 555 U.S. 135 (2009) (exclusionary rule focuses on deterrence and officer culpability)
Illinois v. Wardlow, 528 U.S. 119 (2000) (flight and evasive behavior can be a relevant factor in reasonable‑suspicion analysis)
United States v. Beauchamp, 659 F.3d 560 (6th Cir.) (reasonable suspicion requires non‑ambiguous indicia of criminal activity)
United States v. Keith, 559 F.3d 499 (6th Cir.) (no reasonable suspicion where officers observed ambiguous interactions but no illicit act)
United States v. M. Davis, 514 F.3d 596 (6th Cir.) (framework for assessing Terry stops and reasonable suspicion)
United States v. A. Johnson, 627 F.3d 578 (6th Cir.) (officers’ observation of an apparent hand‑to‑hand exchange in a high‑crime area can support reasonable suspicion)
Michigan v. DeFillippo, 443 U.S. 31 (1979) (probable cause standard for arrests)
United States v. Leon, 468 U.S. 897 (1984) (good‑faith exception to exclusionary rule)