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Name: United States v. Williams
Case #: 15-10008
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/20/2016
Summary

District court erred by suppressing evidence where police had (1) reasonable suspicion to stop defendant based on a reliable tip and the surrounding circumstances, (2) probable cause to arrest defendant for obstructing their attempt to obtain his identity, and (3) probable cause to believe that further evidence of drug dealing would be found in his vehicle. Jones called police and informed them that Williams, a known drug dealer, was asleep in a black Ford outside an apartment complex he did not live at in a high-crime area. Police arrived, blocked the Ford, and illuminated their “take down” lights. Williams tried to back out, but when that failed, exited the car and ran. The officers caught him and found drugs and over $1,000 cash in his pockets. They then searched his car and found a gun. Williams was charged with federal drug crimes and for being a felon in possession of a gun. The district court granted his suppression motion. The government appealed. Held: Reversed and remanded. The Fourth Amendment permits investigatory stops when an officer has reasonable suspicion that the person stopped is engaged in criminal activity. Telephone tips can give officers a reasonable suspicion if they have “sufficient indicia of reliability.” Under the reasoning of Alabama v. White (1990) 496 U.S. 325 and Navarette v. California (2014) 134 S.Ct. 1683, the police had reasonable suspicion to stop Williams based on the information they had and the tip’s reliability. The officers also had probable cause to arrest Williams because he obstructed their attempt to enforce Nevada Revised Statute section 177.123, which permits officers to detain an individual whom they have a reasonable suspicion has committed, is committing, or is about to commit a crime, to obtain his or her identity. By running from police, Williams prevented the officers from discharging their duty under section 177.123. Based on the totality of the circumstances, including the tip and the drugs found on Williams during the search incident to his arrest, the officers had probable cause to believe that further evidence of drug dealing would be found in his vehicle. Therefore, the warrantless search of his car was also valid. The full opinion is available on the court’s website here: https://cdn.ca9.uscourts.gov/datastore/opinions/2016/09/20/15-10008.pdf