On October 22, 2024, the Sixth Circuit Court of Appeals decided the United States v. Williams[i], in which the court examined whether officers violated the Fourth Amendment when they detained a person, handcuffed in the backseat of a police car.  The relevant facts of Williams are as follows:

Williams rear-ended a vehicle at a busy intersection in Grand Rapids, Michigan. The driver of the vehicle that Williams hit, known only as “L.V.,” called the police. When Officers Roxanne Partak and Thomas Gootjes arrived at the accident scene, L.V. told Officer Gootjes that following the accident, Williams immediately jumped out of his car with a backpack, ran into a wooded neighborhood, and returned without the backpack. Williams and his girlfriend were at the scene when the police arrived.

The police also learned that Williams was on federal supervised release. Thereafter, they frisked, handcuffed, and placed Williams in the back of Officer Partak’s patrol car while Officer Gootjes searched for the backpack. Officer Gootjes followed Williams’s footprints in the snow and, twenty-three minutes later, located the backpack in a ravine. In the backpack, Officer Gootjes found marijuana, drug paraphernalia, ammunition, and an empty handgun box. At that point, Officer Partak arrested Williams and confiscated two cell phones in his possession. One of the phones contained photographs and text messages suggesting Williams, a felon, was involved in a firearm transaction.[ii]

Williams was subsequently indicted under federal law for being a felon in possession of a firearm and ammunition.  He filed a motion to suppress the evidence found in the backpack, and the district court denied the motion.  Williams pleaded guilty with the right to appeal the denial of his motion to suppress.

Williams filed a timely appeal to the Sixth Circuit Court of Appeals.

The court of appeals first examined the relevant legal principles and stated

The Fourth Amendment protects against unreasonable searches and seizures. U.S. Const. amend. IV. This protection extends “to brief investigatory stops of persons or vehicles that fall short of traditional arrest.” Campbell, 549 F.3d at 370 (citation omitted). However, an officer may conduct a brief investigatory stop without a warrant if she has reasonable suspicion of criminal activity. See Terry, 392 U.S. at 30. Reasonable suspicion “requires more than a mere hunch” but “less than probable cause.” Campbell, 549 F.3d at 370 (quoting Dorsey v. Barber, 517 F.3d 389, 395 (6th Cir. 2008)). To determine whether reasonable suspicion supported an investigatory stop, we look at circumstances such as an officer’s observations, an officer’s inferences based on her training and experience, dispatch information, and the area where the suspicious activity occurred. Id. at 371; see United States v. Pearce, 531 F.3d 374, 380 (6th Cir. 2008). Additionally, the stop must not exceed its initial scope or last longer than the amount of time necessary to carry out its purpose. Campbell, 549 F.3d at 372; see Dorsey, 517 F.3d at 398. Otherwise, the stop may ripen into an arrest requiring probable cause. Campbell, 549 F.3d at 372. In this reasonable-suspicion analysis, we look at the totality of the circumstances. See United States v. Perez, 440 F.3d 363, 371 (6th Cir. 2006).[iii]

In light of the above principles, the court must first examine whether the officers had reasonable suspicion to detain Williams while they searched for the backpack.  Second, they must determine if the scope or manner of the detention (handcuffed in the backseat of a police car) was reasonable under the Fourth Amendment.

Williams’ detention is governed by the rules regarding Terry stops.  A Terry stop must be justified at its inception, which means there must be reasonable suspicion of criminal activity.  A Terry stop must also be reasonable in scope, which means the manner in which the person is detained and the length of the detention must be reasonable.

On appeal, Williams argued that his prolonged detention while the police searched for the backpack was not reasonable.  The court first examined whether the officers had reasonable suspicion to believe that Williams was involved in criminal activity, such as required to support his additional detention beyond the traffic crash investigation.  The court noted the following relevant facts: (1) the officers were called to the scene when Williams rear-ended another vehicle in a traffic accident; (2) the officers were told by a witness that, after the crash, Williams fled the accident scene with a backpack and returned to the scene without the backpack, before the police arrived; and (3) the police learned that Williams was on federal supervised release.  This amounted to reasonable suspicion to detain Williams while the officer searched for the backpack.

The court also examined whether it was reasonable to place Williams in the backseat of the police car while one officer searched for the backpack.  The court noted that Williams initially fled the scene and disposed of a backpack before the police arrived; therefore, the court said that the officers could reasonably believe Williams still posed a flight risk.  Additionally, the area was busy, and Williams’s girlfriend was also present; as such, while one officer searched for the backpack, the other officer was alone with Williams and his girlfriend, outnumbered.  Further, Officer Partak, who waited with Williams during the search, was smaller than Williams.  The court of appeals noted that they have previously held

[H]andcuffing does not affect the legitimacy of the Terry stop as long as the facts justify the precaution.  See United States v. Sheckles, 996 F.3d 330, 345 (6th Cir. 2021)[iv]

In Williams’s case, the court held that the circumstance of his flight risk, the officer being alone with him and his girlfriend, and the other facts discussed, justified the safety precaution of placing him handcuffed, in the backseat of the police vehicle, as an officer searched for the backpack.

The court of appeals also considered the twenty-three-minute length of the detention as the officer searched for the backpack.  The court of appeals stated

Such a short twenty-three-minute detention falls well short of transforming a Terry stop into an arrest. See Sheckles, 996 F.3d at 345 (collecting cases to support that “under Terry, we and other courts have repeatedly upheld vehicle stops of less than (and sometimes even more than) an hour”).[v]

Thus, the court held that twenty-three-minute detention of Williams was reasonable in this case.

Therefore, the court of appeals held that Williams’s detention did not violate the Fourth Amendment.

Williams also argued that the seizure of his cell phones violated the Fourth Amendment.  The court of appeals noted that, after the backpack was located, the officers had probable cause to arrest Williams for firearms related crimes and violating his supervised release.  Therefore, the search of Williams’s person was a search incident to a lawful arrest, and the seizure of his cell phones was permissible as part of that search.

As such, the court of appeals upheld the denial of the motion to suppress.

Note:  Court holdings can vary significantly between jurisdictions.  As such, it is advisable to seek the advice of a local prosecutor or legal adviser regarding questions on specific cases.  This article is not intended to constitute legal advice on a specific case.

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Citations

[i] No. 23-1839 (6th Cir.  October 22, 2024 Unpublished)

[ii] Id. at 1-2

[iii] Id. at 3-4 (emphasis added)

[iv] Id. at 7 (emphasis added)

[v] Id. at 8