In United States v. Gibbs, No. 17-12474 (Mar. 6,
2019) (Marcus, Dubina, Goldberg), the Court upheld the denial of a
motion to suppress.
Officers observed a vehicle drive into oncoming traffic and
illegally park in the middle of the street.
Officers approached the vehicle, with its engine still running, and effectively
blocked in (and thus detained) two individuals who had just exited the
car. As the officers approached, with
their guns drawn, the defendant blurted out that he possessed a firearm. The Court first determined that the officers
had a lawful basis to detain both men, as the situation arose out of a lawful
traffic stop. The officers were
justified in briefly detaining the defendant, even though he was not the
driver, because based on their location in between cars, the officers could not
have detained the driver without also detaining the defendant, and one of the
officers did not know at the time which individual was the driver. Emphasizing the very brief detention and the
dangers associated with traffic stops, the Court determined that the detention was not
unreasonable under the particular facts and circumstances of the case. Finally, the Court determined that the
officers did not convert the lawful stop into an unlawful one merely by drawing
their weapons; rather, the lawfulness of the encounter turned on the validity
of the stop, which was lawful.
