Justia District of Columbia Court of Appeals Opinion Summaries

On the evening of September 10, 2018, Metropolitan Police Department officers received a ShotSpotter alert indicating a possible gunshot near their location. Shortly after, they encountered Maurice Mitchell riding a bicycle away from the general area of the alert. The officers testified that Mitchell flinched and increased his speed upon noticing their patrol car. They followed him, activated their emergency lights, and stopped him. Upon approaching Mitchell, they observed a firearm protruding from an open bag on his bicycle. Mitchell was subsequently convicted of multiple firearm-related offenses following a stipulated trial.The Superior Court of the District of Columbia denied Mitchell's motion to suppress the firearm, ruling that the officers had reasonable suspicion to stop him based on his proximity to the ShotSpotter alert, his evasive behavior, and the lateness of the hour. Mitchell was convicted and sentenced to eighteen months of incarceration, suspended as to all but twelve months, followed by supervised release and probation. He appealed the denial of his motion to suppress, arguing that the stop was unlawful due to a lack of particularized and articulable suspicion.The District of Columbia Court of Appeals reviewed the case and concluded that the officers lacked reasonable, articulable suspicion to stop Mitchell. The court found that the factors cited by the trial court, including Mitchell's proximity to the ShotSpotter alert, his attire, and his behavior, were insufficient to justify the stop. The court emphasized that the totality of the circumstances did not provide a particularized and objective basis for suspecting Mitchell of criminal activity. Consequently, the court reversed the trial court's denial of the motion to suppress, vacated Mitchell's convictions, and remanded the case for further proceedings consistent with its opinion. View "Mitchell v. United States" on Justia Law