{"id":21860,"date":"2016-04-25T08:05:14","date_gmt":"2016-04-25T13:05:14","guid":{"rendered":"http:\/\/fourthamendment.com\/?p=21860"},"modified":"2016-04-25T08:05:14","modified_gmt":"2016-04-25T13:05:14","slug":"ca4-officer-had-more-than-just-criminal-history-for-rs-here-high-crime-area-and-gang-affiliation-were-important","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=21860","title":{"rendered":"CA4: Officer had more than just criminal history for RS here; high-crime area, and gang affiliation were important"},"content":{"rendered":"<p>The officer had more than just criminal history to find reasonable suspicion to extend the stop. \u201cSignificantly, 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 \u2018narcotics distribution.\u2019 &#8230; 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, \u2018an officer can couple knowledge of prior criminal involvement with more concrete factors in reaching a reasonable suspicion of current criminal activity.\u2019 &#8230; At minimum, such \u2018concrete factors\u2019 in this situation included the overwhelming odor from multiple air fresheners and Palmer&#8217;s apparent gang membership.\u201d <a href=\"http:\/\/www.ca4.uscourts.gov\/Opinions\/Published\/144736.P.pdf\">United States v. Palmer<\/a>, 2016 U.S. App. LEXIS 7224 (4th Cir. April 21, 2016).*<\/p>\n","protected":false},"excerpt":{"rendered":"<p>The officer had more than just criminal history to find reasonable suspicion to extend the stop. \u201cSignificantly, Officer Ring learned, early in the traffic stop, that Palmer was a suspected member of the Bounty Hunter Bloods. Ring knew that the &hellip; <a class=\"more-link\" href=\"https:\/\/fourthamendment.com\/?p=21860\">Continue reading <span class=\"meta-nav\">&rarr;<\/span><\/a><\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[35],"tags":[],"class_list":["post-21860","post","type-post","status-publish","format-standard","hentry","category-reasonable-suspicion"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21860","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=21860"}],"version-history":[{"count":1,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21860\/revisions"}],"predecessor-version":[{"id":21861,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/21860\/revisions\/21861"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=21860"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=21860"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=21860"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}