CA2: RS of man menacing with a gun supported stop at gunpoint

“In this case, in which defendant Justin Patterson stands charged with one count of being a felon in possession of a firearm, see 18 U.S.C. § 922(g)(1), the government appeals from an order … suppressing the charged firearm because it was seized in circumstances amounting to an arrest not supported by probable cause. The government argues that Patterson’s initial detention in a motor vehicle was not an arrest but an investigatory stop supported by the requisite reasonable suspicion and that circumstances highlighted by the district court in finding an arrest—specifically, police officers pointing firearms at, shouting toward, and blocking an exit route for the motor vehicle being driven by Patterson—were reasonable safety precautions given that the officers were investigating a report of menacing with a firearm. We agree.” (Summary by the court.) United States v. Patterson, 2022 U.S. App. LEXIS 3202 (2d Cir. Feb. 4, 2022).