CA4: Officer had more than just criminal history for RS here; high-crime area, and gang affiliation were important

The officer had more than just criminal history to find reasonable suspicion to extend the stop. “Significantly, Officer Ring learned, early in the traffic stop, that Palmer was a suspected member of the Bounty Hunter Bloods. Ring knew that the Bloods had threatened law enforcement during his service as a police officer and that such gangs are frequently involved in organized criminal activity such as ‘narcotics distribution.’ … Ring also ascertained that Palmer had at least four earlier arrests on drug charges and was probably a convicted felon. Indeed, he had been charged previously as a felon in possession of a firearm. As we explained in United States v. Sprinkle, ‘an officer can couple knowledge of prior criminal involvement with more concrete factors in reaching a reasonable suspicion of current criminal activity.’ … At minimum, such ‘concrete factors’ in this situation included the overwhelming odor from multiple air fresheners and Palmer’s apparent gang membership.” United States v. Palmer, 2016 U.S. App. LEXIS 7224 (4th Cir. April 21, 2016).*