United States v. Stephen G. House, 2012 U.S. App. LEXIS 12596

House was a Federal Protective Service officer supervising federal property; he conducted multiple traffic stops outside federal property without authority per policy, wore a federal insignia, and operated marked/unauthorized emergency vehicles.
Indictment charged eight counts of willful deprivation of rights under 18 U.S.C. § 242 and four counts of false statements under 18 U.S.C. § 1001 relating to specific stops and incident reports.
Government presented testimony from former and current FPS officers about policy limits on traffic stops and the obligation to file truthful incident reports; House had prior reprimands for policy violations.
Victims testified that House’s stops were conducted without probable cause or reasonable suspicion, and House filed incident reports containing false statements.
District court gave instructions treating lack of jurisdiction as per se unreasonableness and allowed a balancing approach; conviction verdicts on some counts were challenged on appeal.
Court vacated four counts (one, two, three, six) and affirmed eight counts (four, five, seven, eight, nine, ten, eleven, twelve); remanded for proceedings consistent with opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there was sufficient evidence for willful seizures and false statements	House	House	Sufficient evidence supported some convictions; four seizures vacated for error.
Whether jury instructions on unreasonableness and willfulness were correct	House	House	District court erred in a Fourth Amendment instruction about lack of jurisdiction, but error was harmless as to several counts.
Whether district court interjected itself into trial	House	House	Not plainly reversible; isolated comments not enough to deny fair trial.
Whether evidence was properly excluded	House	House	Evidence exclusions were proper; not reversible errors.
Whether there was cumulative error affecting fairness	House	House	No reversible cumulative error found.

Whren v. United States, 517 U.S. 806 (1996) (traffic stop valid with probable cause or reasonable suspicion despite policy limits)
Virginia v. Moore, 553 U.S. 164 (2008) (state law/policy non-bar to reasonable traffic stops under Fourth Amendment)
Mendenhall, 446 U.S. 544 (1980) (seizure defined by show of authority and submission to it)
Brower v. County of Inyo, 489 U.S. 593 (1989) (seizure by force is prohibited when coercive)
Calif. v. Hodari D., 499 U.S. 621 (1991) (show of authority plus submission required for seizure)