E.D.Mich.: Navarette-like stop was reasonable in shots fired call and that also supported vehicle search for weapon under Long

“Navarette supports a finding of reasonable suspicion here. In light of the totality of the circumstances, including that officers spotted the white pickup in close proximity to the park soon after being dispatched, the court finds that the 911 call was sufficiently reliable to provide officers with reasonable suspicion to stop Bonner’s truck. Given the caller’s report that the driver had shot his gun at a city park, the officers also reasonably suspected that Bonner was armed and dangerous, thus justifying a Terry frisk and protective sweep of the vehicle in order to protect officer safety. See Long, 463 U.S. at 1051-52. Even when a suspect is detained by officers during a stop, such protective sweeps are justified because of the possibility that the suspect may break away or, if he is not arrested, ‘he will be permitted to reenter his automobile, and he will then have access to any weapons inside,’ thus putting officer and public safety at risk. Id. at 1052.” United States v. Bonner, 2020 U.S. Dist. LEXIS 29406 (E.D. Mich. Feb. 20, 2020).

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