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Criminal Law: Felon in Possession of Firearm-Motion to Suppress-Reasonable Suspicion
Staff Report//May 7, 2026//
Defendant appealed his conviction for being a felon in possession of a firearm, challenging the denial of his motion to suppress. Defendant was arrested after police on patrol heard a bottle hit the ground and then observed the bottle near a vehicle with the passenger window rolled down. When the officers approached the vehicle, defendant stepped out, and the officers observed a bulge in his waistband. Defendant refused to submit to a pat-down and instead fled the scene.
Where the totality of the circumstances supported the officers having reasonable suspicion that defendant had violated state littering laws, they had a sufficient basis to detain defendant.
Judgment is affirmed.
U.S. v. Gatnoor (MLW No. 84709/Case No. 25-2052 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of South Dakota, Lange, J.
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