U.S. v. Yancey

In prosecution on unlawful possession of firearm charge, Dist. Ct. did not err in denying defendant’s motion to suppress firearm seized from defendant during traffic stop in which defendant was passenger in vehicle. Record showed that: (1) after driver had been handcuffed and placed in squad car, defendant asked several times if he could leave scene; (2) police, who had prior contacts with defendant and who had been alerted in recent police meeting that defendant might be armed, consistently directed defendant to stay at scene while they attempted to verify that he had valid driver’s license to take possession of arrested driver’s vehicle; (3) while said inquiry was still ongoing, officer directed defendant to exit vehicle for purposes of conducting protective pat-down; and (4) before police could conduct pat-down, defendant fled scene, and police discovered handgun in defendant’s waist during subsequent chase. Reasonable justification existed to continue traffic stop after driver had been apprehended due to police attempt to verify that defendant had valid driver’s license, and thus officers had legal justification to detain defendant for duration of traffic stop, which included subsequent inquiry into his driver's license status. Moreover, govt. could use handgun at trial because traffic stop had not concluded at time defendant had fled scene and revealed existence of handgun during subsequent chase.