United States v. Williams, No. 22-1024 (6th Cir. 2023)
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Michigan State Police Officer Lay, stationed about 35 miles from the Indiana state line, noticed a vehicle driving northbound following closely behind another vehicle—a state law infraction. Lay began following the vehicle and ran its plate through a database, which noted that the car had been in Texas, one day before. Lay pulled the vehicle over and approached. Unprompted, the passenger handed over his driver’s license without making eye contact. The driver produced his driver’s license and a car rental agreement. Returning to her cruiser, Lay ran the information through databases and radioed for assistance. The driver’s name came up clean; the passenger was on probation for a prior crime. Meanwhile, Officer Bierema arrived with his drug-detection K-9. Approximately seven minutes into the stop, Lay exited her cruiser to speak with the passenger about his probation status; he was less than forthcoming. Lay requested consent to search the car, which the driver withheld. She then ordered him to stand back while Bierema’s K-9 conducted a sniff of the vehicle’s exterior. The K-9 alerted to the presence of drugs, prompting the officers to search the car. In the back seat, they found two gym bags containing cocaine and methamphetamine.
The Sixth Circuit affirmed the denial of the defendants’ motions to suppress, rejecting arguments that the traffic stop was unconstitutionally overlong and that the driver’s arrest was unsupported by probable cause.
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