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Mitchell v. United States, 314 A.3d 1144

Facts

On September 10, 2018, Metropolitan Police Department officers received a ShotSpotter alert indicating a possible gunshot. Shortly after, they encountered Maurice Mitchell biking away from the area of the alert. The officers activated their emergency lights and stopped Mitchell, who raised one hand in response to their commands. Upon approaching him, the officers observed a firearm in a bag on his bicycle, leading to his arrest. Mitchell later filed a motion to suppress the evidence obtained during the stop, which was denied by the trial court.

On September 10, 2018, MPD Officers Karina Phillip and Willmino Pantaleon were inside their marked patrol car in an alley near the 2400 block of 4th Street Northeast when the ShotSpotter app on Officer Phillip's MPD phone alerted. The ShotSpotter app indicated that a single shot had possibly been fired at 2316 4th Street Northeast. Though the officers were located '[a]bout a block or a block and a half away,' neither officer heard a gunshot.

Issue

Did the police officers have reasonable suspicion to justify the investigatory stop of Maurice Mitchell?

Rule

An officer may conduct a brief stop for investigatory purposes when there is reasonable suspicion supported by specific and articulable facts that the individual is involved in criminal activity. Reasonable suspicion requires more than a mere hunch and must be particularized and objective as to the individual stopped.

It is well-established … that, consistent with the Fourth Amendment, an officer may conduct a brief stop (a seizure) 'for investigatory purposes' when he has 'reasonable suspicion supported by specific and articulable facts that the individual is involved in criminal activity[.]'

Analysis

The court analyzed whether the officers had reasonable suspicion based on the totality of the circumstances. It concluded that the factors cited by the trial court, including Mitchell's proximity to the ShotSpotter alert and his behavior, did not provide sufficient grounds for reasonable suspicion. The elapsed time since the alert and the lack of additional evidence of criminal activity led the court to determine that the officers' stop was unjustified.

Under this standard of review, we conclude that the officers lacked reasonable, articulable suspicion to stop Mr. Mitchell. The trial court summarized the principal factors justifying the stop as: (1) Mr. Mitchell was close in time and place to the ShotSpotter alert at a late hour; (2) Mr. Mitchell was the only person that the officers observed in the area as he was biking away at a fast pace from the general direction of the ShotSpotter; (3) Mr. Mitchell was dressed in all black clothing and wearing a ski mask; and (4) Mr. Mitchell flinched and increased his biking speed when he observed the officers exiting the alley in their patrol car.

Conclusion

The Court of Appeals reversed the trial court's judgment, vacated Mitchell's convictions, and granted the motion to suppress the evidence obtained during the unlawful stop.

For the foregoing reasons, we conclude that the police did not have the requisite reasonable suspicion to stop Mr. Mitchell. We therefore reverse the judgment of the trial court, grant the motion to suppress, and vacate Mr. Mitchell's convictions for unlawful possession of a firearm (prior conviction), carrying a rifle or shotgun, possession of unregistered firearm, unlawful possession of ammunition, and wearing a hood or mask while engaged in unlawful conduct.

Who won?

Maurice Mitchell prevailed in the case because the court found that the police lacked reasonable suspicion to justify the stop, leading to the suppression of evidence and vacating of his convictions.

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