United States v. Rickmon, No. 19-2054 (7th Cir. 2020)
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ShotSpotter's surveillance system uses microphones to record gunshots. An individual determines whether the sound is a shot. When that individual confirms a gunshot, ShotSpotter contacts local police. At 4:40:02 a.m., ShotSpotter reported gunshots coming from North Ellis Street. Peoria Officer Ellefritz, driving toward the address, heard the dispatcher report a second ShotSpotter alert of more shots fired. Ellefritz, the first responding officer, saw headlights leaving North Ellis, coming his way. He activated his emergency lights and shouted “stop.” Within seconds, the car stopped next to Ellefritz’s cruiser; its occupants pointed backward, yelling: “They are down there!” Ellefritz observed 15–20 people at the street’s dead end, approximately 300 feet from him. Ellefritz kept his firearm drawn. The driver and the passenger, Rickmon, kept their hands up until backup arrived. Rickmon then stated that someone had shot him in the leg. With the driver’s consent, Ellefritz searched the automobile and found a handgun under Rickmon's seat.
Rickmon was charged with possession of a firearm by a felon. Ellefritz testified that there was nothing particularly unusual about this car, except leaving the area of the gunfire. The Seventh Circuit affirmed the denial of a motion to suppress. The totality of the circumstances provided the officer with reasonable suspicion of criminal activity to justify the stop.
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