US v. Daniel Critchfield, No. 22-4063 (4th Cir. 2023)
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A federal grand jury indicted Defendant for possessing a firearm while being an unlawful user of a controlled substance. Defendant moved to suppress the firearm and other physical evidence, arguing that the officers lacked reasonable suspicion for the stop. After the district court denied his motion, Defendant entered a conditional guilty plea that preserved his right to appeal the suppression ruling.
The Fourth Circuit vacated Defendant’s conviction and remanded for further proceedings. The court held that the officers lacked reasonable suspicion of criminal activity when they first detained Defendant. The court explained that in considering the totality of the circumstances known to the officers when they stopped Defendant, it concludes the officers did not have objectively reasonable suspicion that Defendant was, or had been, engaged in theft. The court wrote that when the officers stopped Defendant, they knew he was a man with a weighed-down sweatshirt pocket who had walked through a residential neighborhood past an occasionally unoccupied home next to a commercial area in broad daylight and who had behaved evasively when a neighborhood resident watched and followed him. These circumstances, without more, do not give rise to reasonable suspicion of theft. As such, the court held that at bottom, the totality of the circumstances does not support a reasonable, articulable suspicion that Defendant had engaged, or was about to engage, in theft.
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