Appellate Clinic Argues Before Fourth Circuit in U.S. v. Charles Williams, Jr.
News from the Appellate and Supreme Court Clinic
On September 16, 2015, Amber Will, 3L, argued before the United States Court of Appeals for the Fourth Circuit on behalf of the appellant, Mr. Charles Williams, Jr. The case involved a Fourth Amendment violation when police officers continued to detain Mr. Williams after a traffic stop in order to conduct a drug investigation. The traffic stop violated Mr. Williams' right against unconstitutional seizure by both (1) releasing Mr. Williams and stopping him again without any new evidence, and (2) unlawfully extending a traffic stop for speeding into a drug investigation without sufficient indicia of criminal drug activity.
The Fifth, Eighth, and Tenth Circuits already have ruled that after releasing someone from a stop, police officers must have an articulable and reasonable suspicion to justify a second stop. Basically, the police need to observe something new between the first and second stops for a second stop to be allowed. This rule prevents police officers from continuously stopping individuals based off of observations from one traffic stop. In this case, the police officers did not observe any new evidence to justify detaining Mr. Williams a second time.
Regardless, the officers did not have have objective reasonable suspicion of criminal activity to justify extending a routine traffic stop into a drug investigation. Because the district court relied upon only four benign factors, the totality of circumstances did not show that Mr. Williams was engaged in any kind of criminal activity. Thus, any extension of the traffic stop was likewise unlawful under the Fourth Amendment.
The panel of judges for the argument consisted of Judge Robert Bruce King, Judge Barbara Milano Keenan, and Judge Henry Franklin Floyd. During the opening 17-minute argument, they asked Amber numerous questions regarding the reasonable suspicion analysis. No questions were asked during the brief rebuttal. The Court will issue its decision in the coming months. The argument can be heard here.