Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm. Miller appeals the case, arguing that officers unlawfully extended the stop and the subsequent frisk was not supported by reasonable suspicion.

The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed.

Us v. Miller

During a PC search of Charles’ vehicle, a Glock handgun was located with a 3D printed device attached to it which allowed the firearm to operate in a fully automatic manner. Charles was charged with unlawful possession of a machine gun. Charles filed an appeal stating that his 2nd amendment right allowed him to “bear arms”.

The appelate court decided Charles possession of the “machine gun” is not protected by the Second Amendment. Machine guns are not in common use by law-abiding citizens for lawful purposes and therefore fall within the category of dangerous and unusual weapons that the government can prohibit for individual use.

US v. Charles

Defendant had sold pills containing fentanyl to someone working with an undercover officer on 9/20/2023. Later the same day, officers responded to Williams’s apartment for a report of a domestic. Officers located drugs, paraphernalia, and later two firearms in his vehicle. Williams was charged with possessing a dangerous weapon in connection with a drug trafficking offense. Williams argues that the court erred in its ruling that the enhancement did not apply since the firearms were not related to the drug transaction.

The district court did not clearly err in making the finding that the two-level enhancement applied. See United States v. Young, 689 F.3d 941, 946 (8th Cir. 2012) (“[T]he presence of a firearm in a location where it could be used to protect drugs can be sufficient evidence to prove the requisite connection.”).

US v. Tyree Williams

Ray Calvert was driving a rental car when an Arkansas state trooper stopped him for illegal lane changes. While waiting for dispatch to run criminal history reports, the passenger who rented the car consented to a search. The trooper found 2- bundles of methamphetamine in the glove box. After the district court denied Calvert’s motion to suppress the evidence, he pleaded guilty to possession with intent to distribute a controlled substance. Calvert argues that the stop was unconstitutional. He claims he didn’t commit a traffic violation, so the trooper lacked reasonable suspicion for the stop. Calvert also claims that the trooper unreasonably prolonged the stop.

the district court credited the trooper’s testimony that he believed Calvert illegally changed lanes. That finding is not clearly erroneous, and a traffic violation justifies a stop. (“Any traffic violation, however minor, provides probable cause for a traffic stop.” (citation omitted)); United States v. Herrera-Gonzalez, 474 F.3d 1105, 1109 (8th Cir. 2007) (even an officer’s mistaken belief that a violation occurred can justify a stop as long as the belief was objectively reasonable). An officer may detain a motorist while completing “certain routine tasks related to the traffic violation,” including checking drivers’ licenses and criminal histories. Here, twelve minutes into the stopand before dispatch had returned the criminal history check, the passenger consented to a search. The trooper could extend the stop while he conducted the search. United States v. Rivera, 570 F.3d 1009, 1013 (8th Cir. 2009) (when motorist consents to search, “he necessarily consents to an extension of the traffic stop while the search is conducted”).

US v. Calvert

Shue Moua was convicted by a jury of possession with intent to distribute methamphetamine. The conviction stemmed from a traffic stop conducted by Deputy Nils Hansen, who observed Moua’s erratic behavior at a gas station and suspected she was impaired. During the stop, Hansen noted several signs of impairment and discovered methamphetamine in Moua’s vehicle during an inventory search after her arrest. Moua moved to suppress the evidence obtained from the search, arguing that the traffic stop was invalid and unreasonably prolonged. A magistrate judge recommended granting the motion, finding that Hansen lacked reasonable suspicion to initiate the stop.

the United States District Court for the District of Minnesota overruled this recommendation, concluding that Hansen had reasonable suspicion based on Moua’s impaired behavior and vehicle registration issues. The district court also found that the stop was not unreasonably extended. The United States Court of Appeals for the Eighth Circuit reviewed the case and upheld the district court’s decision. The appellate court found that Deputy Hansen had reasonable suspicion to stop Moua’s vehicle based on her erratic driving and the absence of visible registration tags. The court also determined that the stop was not unreasonably prolonged, as Hansen’s suspicions evolved during the encounter, justifying further investigation.

US v. Moua

Britt Lander was stopped by police in June 2022, and drug paraphernalia and methamphetamine were found in his vehicle. After being read his Miranda rights, Lander requested the presence of his partner, whom he jokingly referred to as his attorney. The officer denied this request and continued the interrogation, during which Lander made incriminating statements about his involvement in methamphetamine trafficking. Lander was subsequently indicted for conspiring to distribute methamphetamine after a prior felony drug conviction.

The United States District Court for the Northern District of Iowa denied Lander’s motion to suppress his statements, concluding that his waiver of Miranda rights was voluntary and that his request for his partner was not a clear invocation of his right to counsel. The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that Lander’s waiver of his Miranda rights was voluntary, as he appeared to understand the situation despite his claims of intoxication and sleep deprivation. The court also found that Lander’s request for his partner was not a clear and unequivocal request for an attorney.

US v. Lander

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.

The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated.

Maser v. City of Coralville

Tayvin Galanakis sued Officers Nathan Winters and Christopher Wing alleging they arrested him without probable cause. The district court denied summary judgment in part, determining that the officers were not entitled to qualified immunity or state statutory immunity, and the City was subject to vicarious liability on a surviving state-law claim.

The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on Galanakis’s Fourth Amendment claim, concluding that no objectively reasonable officer could have concluded that there was a substantial chance Galanakis had driven while under the influence of marijuana. The court found that Galanakis evinced almost no indicia of intoxication and that his behavior during the stop did not suggest impairment.

Galanakis v. City of Newton

Devin Ledbetter was seriously injured by Springfield, Missouri police officer Brandon Helmers. Ledbetter sued Helmers claiming Helmers used excessive force in violation of the Fourth Amendment. The incident occurred when Helmers and his partner responded to a 911 call about a man holding a woman captive in a tent. Ledbetter, who was in the tent, exited holding a knife. The accounts of what happened next differ, with Helmers claiming Ledbetter was non-compliant and threatening, while Ledbetter claimed he immediately dropped the knife and was compliant. Ledbetter sustained severe injuries, including a fractured hip, during the arrest.

The United States District Court for the Western District of Missouri denied Helmers’s motion for summary judgment based on qualified immunity, noting disputed facts about the threat Ledbetter posed and the amount of force used. The case proceeded to trial, but the jury could not reach a verdict on liability. However, they answered special interrogatories, finding Helmers reasonably believed Ledbetter posed an immediate threat but did not believe Ledbetter was resisting arrest. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Helmers used excessive force, given the evidence and the jury’s special findings. However, the court also held that it was not clearly established that Helmers’s use of force was excessive under the circumstances, as existing case law did not provide sufficient guidance for the specific situation Helmers faced. Therefore, the court affirmed the district court’s judgment granting Helmers qualified immunity.

Ledbetter v. Helmers