United States v. Knights, No. 19-10083 (11th Cir. 2020)
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The Eleventh Circuit affirmed the district court's denial of defendant's motion to suppress the evidence officers found in an investigatory stop and the statements he made to the officers. In this case, the officers saw defendant and another individual at 1:00 a.m. in a car that was parked in the front yard of a home; suspecting that the men might be trying to steal the car, the officers parked near it and approached defendant, who was in the driver's seat; when defendant opened the door, an officer immediately smelled marijuana; and an ensuing search of the car revealed ammunition and firearms.
The court held that the officers did not violate defendant's right to be free from unreasonable seizures because defendant's interactions with the officers was an initially consensual encounter that did not implicate the Fourth Amendment. The court stated that a reasonable person in defendant's position would have felt free to leave. Here, the officers parked alongside the car with enough space for him to drive away. When the officers approached defendant to speak to him, they did not convey that defendant was required to comply. Defendant's other arguments to the contrary are unpersuasive. Finally, the court noted that, although the presence of multiple officers and the age and race of a suspect may be relevant factors, the totality of the circumstances establish that this encounter was not coercive.
The court issued a subsequent related opinion or order on March 10, 2021.
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