United States v. Thomas, 997 F.3d 603

Dallas officers used an ALPR to locate a silver Toyota Camry reported stolen in an aggravated robbery involving a firearm.
They found the Camry in a parking spot with two people inside and four others standing nearby; Pizarro Thomas stood nearest the driver’s-side front tire and was interacting with the group.
Officers confirmed the plate via NCIC, returned, drew weapons, ordered everyone to the ground, and handcuffed four of six (including Thomas) for roughly ten minutes.
During a protective frisk of Thomas, Officer Hovis discovered a loaded, stolen firearm on Thomas; a later search incident to arrest found cocaine.
Thomas was indicted for being a felon in possession, moved to suppress the firearm as the fruit of an unconstitutional stop/frisk and excessive detention, lost in the district court, was convicted after a bench trial, and appealed only the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Reasonable suspicion to stop and frisk Thomas	Terry stop lawful: high-crime area + proximity to a stolen vehicle + interaction with occupants gave particularized suspicion	Mere presence near a stolen car and talking to occupants is not individualized suspicion; proximity alone insufficient	Affirms: totality (proximity, interaction, high-crime, stolen-vehicle tied to armed robbery) gave reasonable suspicion to stop and frisk Thomas
Whether officers’ tactics converted the stop into a de facto arrest requiring probable cause	Use of firearms, ordering to ground, and handcuffing were reasonable safety measures during a Terry detention	Such force and restraints converted the stop into an arrest absent probable cause	Affirms: under the circumstances (outnumbered, violent underlying offense) the measures were reasonable and did not convert the stop into an arrest
Effect of Dallas PD policy barring officers from questioning suspects about the robbery	Departmental policy does not alter constitutional analysis; officers may still conduct Terry stops under the Fourth Amendment	Because policy prevented investigatory questioning, officers lacked an investigatory purpose and thus Terry justification fails	Affirms: departmental rules are irrelevant to Fourth Amendment validity; policy does not negate an otherwise constitutional Terry stop

Terry v. Ohio, 392 U.S. 1 (establishes stop-and-frisk standard)
United States v. Cortez, 449 U.S. 411 (totality-of-circumstances for reasonable suspicion)
United States v. Arvizu, 534 U.S. 266 (aggregate innocuous facts can form reasonable suspicion)
Arizona v. Johnson, 555 U.S. 323 (limits and scope of Terry stop and frisk)
Ybarra v. Illinois, 444 U.S. 85 (mere propinquity to suspects does not supply individualized suspicion)
Maryland v. Pringle, 540 U.S. 366 (permitting inference of joint knowledge/control among vehicle occupants)
Kansas v. Glover, 140 S. Ct. 1183 (reasonable-suspicion standard permits commonsense inferences)
United States v. McKinney, 980 F.3d 485 (5th Cir.) (distinguishing proximity in high-crime areas where no nexus to crime)
Hensley v. Carter, 469 U.S. 221 (safety measures to maintain status quo during stops)