United States v. Williams
846 F.3d 303
| 9th Cir. | 2016Background
- At ~4:40 a.m., a named caller (Tony Jones) reported to a police hotline that a Black adult male sleeping in a gray Ford Five Hundred in an apartment complex parking lot was "known to sell drugs" and did not live there; caller gave name, address, and phone.
- Officers Hubbard and Keller arrived, found the described car with temporary plates, blocked it, and illuminated the vehicle; Williams sat up, looked around, started the car briefly, then exited when ordered.
- Williams fled on foot when officers approached; he was chased, fell, secured, handcuffed, and subjected to a pat-down during which officers found individually wrapped crack cocaine and $1,165 in cash.
- Officers returned to the Ford, searched it, found a purse containing a handgun, and later learned the car was registered to a company (not Williams); they called a firearms detective.
- Williams was indicted on federal charges (felon in possession, drug possession with intent to distribute, and a §924(c) firearm enhancement); he moved to suppress the cocaine and firearm; the district court granted suppression.
- The government appealed; Ninth Circuit reversed, holding the stop, arrest, search-incident-to-arrest, and warrantless vehicle search were lawful and remanded.
Issues
| Issue | Williams' Argument | Government's Argument | Held |
|---|---|---|---|
| Whether officers had reasonable suspicion to stop/detain Williams | The tip was unreliable/insufficient (citing J.L.); mere description plus presence in a high-crime area is inadequate | Tip was reliable: named caller, provided identifying info, predictive/verifiable details; officers corroborated and observed furtive conduct | Officers had reasonable suspicion; stop lawful |
| Whether officers had probable cause to arrest Williams after he fled | Flight alone supports only reasonable suspicion, not probable cause to arrest for obstruction | Williams obstructed enforcement of NV §171.123 by fleeing when officers sought to ascertain identity; that obstruction supplied probable cause to arrest | Probable cause to arrest for obstructing enforcement of §171.123 existed |
| Whether the search of Williams’ person was lawful (search incident to arrest) | Search exceeded pat-down and was invalid absent lawful arrest | Arrest was lawful; search incident to arrest may extend to inside pockets and was therefore valid | Search incident to lawful arrest was valid; cocaine admissible |
| Whether officers had probable cause to search the vehicle without a warrant | Vehicle search lacked individualized probable cause; arrest was for running/obstruction unrelated to vehicle | Prior tip, Williams’ flight, high-crime/time, and controlled substances/cash found on person gave a fair probability vehicle contained further contraband | Probable cause existed to search vehicle and its containers; vehicle search lawful |
Key Cases Cited
- Navarette v. California, 134 S. Ct. 1683 (2014) (911/eyewitness tips may carry reliability and can supply reasonable suspicion when corroborated)
- Alabama v. White, 496 U.S. 325 (1990) (anonymous tips that predict future actions and are corroborated can justify investigatory stops)
- Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip giving only a description without predictive information cannot justify stop)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (unprovoked flight in a high-crime area is a factor supporting reasonable suspicion)
- United States v. Robinson, 414 U.S. 218 (1973) (search incident to lawful arrest may include searching inside pockets)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause judged by totality of circumstances and fair probability standard)
- United States v. Sokolow, 490 U.S. 1 (1989) (reasonable suspicion is a lower standard than probable cause; totality-of-circumstances analysis)
- United States v. Crawford, 372 F.3d 1048 (9th Cir. 2004) (standard of review for suppression rulings)
- United States v. Edwards, 761 F.3d 977 (9th Cir. 2014) (analysis of tip reliability for investigatory stops)
- United States v. Maddox, 614 F.3d 1046 (9th Cir. 2010) (scope of search incident to arrest)
- United States v. Ewing, 638 F.3d 1226 (9th Cir. 2011) (automobile exception permits warrantless search when probable cause exists)
- United States v. Smith, 633 F.3d 889 (9th Cir. 2011) (discussing flight and reasonable suspicion)
- United States v. Guzman-Padilla, 573 F.3d 865 (9th Cir. 2009) (appellate courts may consider more specific legal theories on appeal if the general claim was presented below)