In United States of America v. Wilbert James Smith, Jr., Docket No. 22-1055, the United States Court of Appeals for the 6th Circuit upheld the decision of a Federal District Court Judge (in Michigan) that there was reasonable suspicion to support an investigatory stop of Smith’s car and, as a result, that the search was lawful. Wilbert Smith was convicted of committing firearm and drug-related offenses. Most of the incriminating evidence was discovered during a search of Smith’s vehicle following a stop by law enforcement. The District Court’s determination that the facts supported a finding of reasonable suspicion for the stop and denying the underlying motion to suppress is reviewed de novo by the 6th Circuit (or in other words anew or from the beginning) or deciding the issues without reference to any legal conclusion or assumption made by the previous court to hear the case. Since the 6th Circuit upheld the decision of the Federal District Court Judge that the stop was lawful they affirm the denial of Smith’s motion to suppress the evidence found during that stop.
As the Court of Appeals explains in their decision, “The Fourth Amendment offers a familiar guarantee: people are to be free from “unreasonable searches and seizures” by the government. U.S. CONST. amend. IV. That pledge is primarily enforced through “the exclusionary rule,” a court-adopted principle that “requires trial courts to exclude unlawfully seized evidence in a criminal trial.” Utah v. Strieff, 579 U.S. 232, 237 (2016). Whether this right has been infringed on is typically addressed at a pre-trial suppression hearing in the district court. Fed. R. Crim. P. 12(b)(3)(C).”
Another helpful explanation by the 6th Circuit in this decision is that “Reasonable suspicion is not particularly difficult to establish. United States v. McAllister, 39 F.4th 368, 373 (6th Cir. 2022); cf. United States v. Arvizu, 534 U.S. 266, 274 (2002) (noting reasonable suspicion is a less burdensome standard than probable cause); United States v. Frechette, 583 F.3d 374, 379 (6th Cir. 2009) (citation and quotation omitted) (explaining that probable cause requires “a fair probability that contraband or evidence of a crime will be found in a particular place.”). In a nutshell, there is reasonable suspicion to stop a car where officers, taking the totality of the circumstances, put forward “a particularized and objective basis for suspecting legal wrongdoing.” Arvizu, 534 U.S. at 273 (quotation marks omitted). In doing so, officers cannot rely on “a mere hunch.” Id. at 274 (quotation marks omitted). But they can “draw on their own experience and specialized training to make inferences and deductions.” Id. at 273–74.”
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