United States v. Mitchell, No. 18-4654 (4th Cir. 2020)
Annotate this CaseThe Fourth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a firearm after defendant conditionally pleaded guilty to possession of a firearm by a felon. The court held that the officer had reasonable suspicion of criminal activity when he stopped and frisked defendant. In this case, a bystander called 911 to report a large fight and assault, with a victim knocked out laying on the ground; the area was known to be a problem area; and officers could reasonably infer from the report that the person with the gun was involved in the fight. The court rejected defendant's contention that the tip from the bystander was unreliable and that the tip insufficiently alleged illegal conduct.
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