United States v. Coleman, No. 20-4093 (4th Cir. 2021)Annotate this Case
As students were arriving at the high school, an administrator reported an unknown man (Coleman, age 39) “asleep or passed out” in his vehicle with a crossbow visible in the backseat. The vehicle, stopped but running, was primarily parked in a travel lane. Deputy Johnson believed possession of the crossbow was illegal under Virginia law because it could fire “a projected missile on the school campus.” During questioning, Coleman stated that he had a firearm in the vehicle’s center console. Johnson asked Coleman to exit the vehicle. When Coleman did so, Johnson observed “a fairly large bag of a green leafy substance that appeared to be marijuana” beside the driver’s seat. Another deputy searched the vehicle, finding marijuana, crystal methamphetamine, individual baggies, a scale, a .38 Special revolver, and the crossbow.
Coleman was among 28 defendants indicted for participating in a drug trafficking organization. Coleman was charged in two drug counts and for using and carrying a firearm during and in relation to a drug trafficking crime. Coleman unsuccessfully moved to suppress the evidence, arguing that Johnson did not have reasonable suspicion of criminal activity to conduct an investigative “Terry” stop because possession of a crossbow on school grounds is not illegal in Virginia. The Fourth Circuit affirmed his convictions and 211-month sentence. Even if Coleman had not possessed the crossbow, Johnson would have had reasonable suspicion to conduct an investigative stop based on the totality of the circumstances.