United States v. Brown, No. 13-2214 (3d Cir. 2014)
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Pittsburgh Police Detectives Emery, Adametz, Kennedy, and Gault were patrolling in an unmarked cruiser and observed a Chevy Impala driven by Brown parking across from a nuisance bar where drug dealing and shootings regularly occur. The detectives believed the Impala was parked too close to the intersection, stopped their cruiser, and watched as Brown and three others exit the Impala. Brown appeared to recognize the unmarked cruiser, sat back down in the Impala, and made a motion consistent with removing an object from his waistband and placing it beneath the seat. Brown then stepped out and walked toward the bar. The detectives believed Brown had removed a gun from his person and attempted to conceal it under the seat. They identified themselves as police officers. Gault informed Brown that the Impala was parked illegally. Emery walked around the car, shined a flashlight through the windshield, and observed “the grip and rear slide portion of a semi-automatic firearm sticking out from underneath the driver’s seat.” The detectives asked Brown whether he had a permit to carry the firearm. Brown answered that he did not. They placed him under arrest and retrieved the gun. Charged as a felon in possession of a firearm, 18 U.S.C. 922(g)(1), Brown unsuccessfully moved to suppress evidence of the gun. The Third Circuit vacated the conviction. While rejecting Brown’s argument that evidence of the firearm should have been suppressed, the court found error in admitting evidence of Brown’s past firearm purchases and by overruling objections to the prosecutor’s closing arguments. The error was not harmless.
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