United States v. Steven Smith
421 F. App'x 572
6th Cir.2011Background
- Steven Smith, a felon, was charged with being a felon in possession after a handgun was found in his brother Christopher's truck.
- A Mansfield, Ohio officer stopped Christopher for turning left without signaling, and Steven fled on foot while Christopher remained.
- Christopher consented to a truck search; the handgun was recovered on the passenger-side floorboard, with Christopher denying knowledge and claiming it belonged to Steven.
- Steven moved to suppress the evidence, arguing the stop was not supported by probable cause and the signaling violation was not valid under state law.
- The district court denied the suppression motion, rejected Lipian’s expert view that signaling was not required, and Steven pled guilty while reserving appeal rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for stop based on signaling | Smith | US | Probable cause existed; signaling violation supported the stop. |
| Whether § 331.14(a) required signaling at the Olivesburg–Wayne intersection | Smith | US | Yes, signaling was required; stop upheld. |
| Use of expert testimony to interpret law | Smith | US | District court did not abuse discretion; expert not needed for pure issues of law. |
Key Cases Cited
- United States v. McPhearson, 469 F.3d 518 (6th Cir. 2006) (de novo review of suppression rulings)
- United States v. Ozuna, 561 F.3d 728 (7th Cir. 2009) (abuse of discretion standard for reconsideration rulings)
- United States v. Brobst, 558 F.3d 982 (9th Cir. 2009) (abuse of discretion review in suppression context)
- United States v. Simpson, 520 F.3d 531 (6th Cir. 2008) (probable cause required for completed misdemeanor violations)
- United States v. Hughes, 606 F.3d 311 (6th Cir. 2010) (probable cause for traffic stops relating to signaling)
- United States v. Akram, 165 F.3d 452 (6th Cir. 1999) (signals and lane-change observations support stop)