United States v. Tyrone Harris, 747 F.3d 1013

Harris, a felon, pleaded guilty conditionally to being in possession of a firearm; the plea reserved suppression issues for appeal.
At the Greyhound bus station in Kansas City, a sleeping Harris had a handgun partially visible from his pocket.
An officer removed the gun for safety and woke Harris, then arrested him on an outstanding Minnesota warrant.
The Greyhound employee requested police assistance due to a dangerous, potentially volatile situation.
The station is in a high-crime area; the gun posed public safety risks.
The district court denied suppression; Harris appeals the denial arguing Fourth Amendment violations

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial encounter lawful under community caretaking?	Harris contends no crime suspicion existed	Officers acted to aid and protect the public	Yes, under community caretaker doctrine
Was the retrieval of the firearm and handcuffing justified?	Seizure without probable cause was unlawful	Actions were reasonably necessary for safety	Yes, reasonable under circumstances
Did discovery of an outstanding warrant provide probable cause for arrest?	Arrest relied on warrant status after initial contact	Identity check and warrant confirmed probable cause	Yes, probable cause existed after warrant revealed

Quezada v. City of Chicago, 448 F.3d 1005 (8th Cir. 2006) (community caretaker emergency justified intrusion)
Winters v. Adams, 254 F.3d 758 (8th Cir. 2001) (caretaker doctrine for emergency situations)
Samuelson v. City of New Ulm, 455 F.3d 871 (8th Cir. 2006) (limits on noninvestigatory seizures under caretaker doctrine)
Garcia v. City of Chicago, 646 F.3d 1061 (8th Cir. 2011) (identity verification during encounter justified to resolve ambiguity)
Brigham City v. Stuart, 547 U.S. 398 (2006) (reasonableness standard for police encounters and safety)
Terry v. Ohio, 392 U.S. 1 (1968) (stop and frisk based on reasonable suspicion; scope limited to safety)