United States v. Buzzard, No. 20-4087 (4th Cir. 2021)Annotate this Case
The Fourth Circuit affirmed the district court's denial of Defendant Buzzard and Martin's motions to suppress evidence found when police searched a car they occupied. Given the totality of the circumstances, the court concluded that the officers' question asking whether there was anything illegal in the vehicle related to officer safety and was therefore related to the traffic stop's mission. In any event, the court concluded that the officer's question did not extend the stop by even a second.
The court also affirmed the district court's denial of Martin's motion for acquittal at trial and the revocation of his term of supervised release at sentencing. The court concluded that the evidence was more than sufficient for the jury to conclude that Martin possessed the guns. Furthermore, because Martin's challenge to the revocation of his prior term of supervised release is based entirely on his assertion that there was no substantial evidence for his conviction, the court likewise affirmed that decision.