U.S. v. Jackson

In prosecution on unlawful possession of firearm by felon based on seizure of firearms found in defendants’ car following traffic stop, Dist. Ct. did not err in denying defendants’ motion to suppress seizure of said firearms, even though defendants asserted that police office lacked probable cause to make instant traffic stop. Record showed that: (1) officer stopped defendants’ car because officer observed 4.7 inch tree-shaped air freshener hanging from rearview mirror; and (2) officer believed that instant air freshener violated Chicago ordinance prohibiting any object obstructing driver’s clear view through windshield. Officer had reasonable suspicion to stop defendant’s vehicle for ordinance violation and had articulable and objective basis for suspecting that air freshener obstructed driver’s view, and thus instant stop was lawful. Fact that officer incorrectly told defendants at time of stop that they could not have anything hanging from rearview mirror did not require different result, since instant reasonable suspicion inquiry is objective standard, such that officer’s subjective motivation for stopping defendant’s car was irrelevant.