United States v. Black, No. 11-5084 (4th Cir. 2013)Annotate this Case
Defendant appealed the district court's denial of his motion to suppress a firearm on the basis that it was the fruit of an unlawful seizure of his person. The court concluded that defendant was seized when his ID was retained while his companions were frisked. The totality of the factors outlined by the district court - an individual's presence at a gas station; prior arrest history of another individual; lawful possession and display of a firearm by another; defendant's submission of his ID showing an out-of-district address; all of which occurred in a high crime area at night - failed to support the conclusion that the officer had a reasonable suspicion to detain defendant. Therefore, the court held that there was no reasonable suspicion justifying defendant's seizure and the district court erred in denying his motion to suppress. Accordingly, the court reversed and vacated defendant's conviction and sentence.
The court issued a subsequent related opinion or order on February 26, 2013.