D.C.Cir.: Def’s sole presence after ShotSpotter report led to RS

A ShotSpotter report led to reasonable suspicion for defendant’s stop. “We conclude that the record facts support the findings of the district court. The totality of the information known to Turner when she stopped Jones sufficed to raise a reasonable suspicion. The ShotSpotter alert and dispatcher report from MPD indicated that shots were fired in the 3500 block of 13th Street Southeast. … Turner and Ennis arrived at the location of the reported gunshots within a minute and a half of the MPD call. Turner testified that they saw that Jones was the only person on that block. … Jones was walking quickly away from the location of the shooting.” United States v. Jones, 2021 U.S. App. LEXIS 17756 (D.C. Cir. June 15, 2021).

In the context of an ineffective assistance claim, defendant’s motion to suppress one cell phone did not apply to his older cell phone that could also access the same data. He didn’t show that granting a motion to suppress the newer phone would apply to the older phone. The independent source rule applies to the older phone. Gordon v. United States, 2021 U.S. App. LEXIS 17809 (6th Cir. June 15, 2021).*