United States v. Williams, No. 18-2747 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after conditionally pleading guilty plea to being a felon in possession of a firearm. The court held that the officer's mistaken belief that the red vehicle at issue was stolen based upon his misreading of the "hot sheets" was objectively reasonable. The court also held that the officers did not impermissibly extend the stop, and thus the observation of narcotics and the firearm, coupled with the inability to identify the vehicle's owner, provided the officers with probable cause to tow the vehicle and perform an inventory search. Therefore, the district court did not err in concluding that the officers had a legally permissible basis to tow and search the vehicle, revealing the firearm that gave rise to the charge against defendant.
Court Description: Shepherd, Author, with Melloy and Grasz, Circuit Judges] Criminal case - Criminal law. Officer's mistaken belief that the car involved was stolen based upon his misreading of a daily list of stolen vehicles was objectively reasonable under the fact presented, and the officer had sufficient reasonable suspicion to perform an investigatory search; given the facts presented, the officers were warranted in continuing the stop after they verified the car was not stolen; expired tags, evasive answers by the bystanders, misrepresentation that the car had been at the address all day and the refusal of any one present to identify the owner all created a reasonable suspicion that criminal activity, separate from auto theft, was afoot; because the officers did not unreasonably extend the stop, their observation of narcotics and a firearm provided them with probable cause to tow the vehicle and perform the inventory search which discovered the weapons which formed the basis for defendant's felon-in-possession charge.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.