United States v. Willis
759 F.2d 1486 (1985)
Rule of Law:
An investigatory seizure of a suspect is justified under the Fourth Amendment if law enforcement has a reasonable suspicion based on specific, articulable facts, including evasive conduct near a crime scene. The duration of such a seizure is permissible as long as police diligently pursue a means of investigation likely to quickly confirm or dispel their suspicions, and it does not become a de facto arrest requiring probable cause.
Facts:
- On August 3, 1983, a Piper Navajo aircraft landed at Montgomery Airport, ignored ground crew signals, and parked in a dark, remote area.
- A man later identified as David Newcomb exited, arranged for fuel, and stated someone would unload the plane later; he and another man, Omar Mahdi, then left the airport.
- Airport linemen observed that the plane was heavily overloaded, had expensive engine modifications, and its cabin was filled with large green duffel bags containing hard, football-sized packages.
- An experienced narcotics officer, Tyrone Anderson, viewed the bags and packages through a window and concluded they likely contained a large amount of cocaine.
- Later that night, Mahdi was found by police walking along a road near the airport.
- Around midnight, a taxi carrying William Willis entered the airport gate. Willis exited the cab, looked toward the plane which was surrounded by police cars and officers, made eye contact with an officer, and immediately re-entered the cab to leave.
- The cab driver later told police that Willis had claimed he was meeting a friend, but then abruptly said he was hungry and asked to be driven back to his motel.
- At the motel, police found Newcomb in possession of a key to one of Willis's rooms, and Willis, after initially providing a conflicting story, admitted he knew Newcomb and the other men present.
Procedural Posture:
- William Willis and Omar Mahdi filed motions to suppress evidence in the United States District Court for the Middle District of Alabama, the court of first instance.
- The district court held a suppression hearing, granting the motion in part and denying it in part.
- Following a jury trial, Willis and Mahdi were convicted on all counts of conspiracy to import and possess cocaine with intent to distribute.
- Willis and Mahdi (appellants) appealed their convictions to the United States Court of Appeals for the Eleventh Circuit, arguing the district court erred in denying their suppression motions.
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Issue:
Does the brief investigatory seizure of a suspect violate the Fourth Amendment when it is based on the collective knowledge of law enforcement about a probable crime and the suspect's evasive actions upon observing police activity at the scene?
Opinions:
Majority - Henderson
No. The brief investigatory seizure of a suspect does not violate the Fourth Amendment when justified by reasonable suspicion. A seizure occurs when a reasonable person would not feel free to leave, which happened when Officer Brown asked Willis to exit the cab and frisked him. This seizure was supported by reasonable suspicion based on several specific, articulable facts: police expected co-conspirators to arrive; Willis appeared late at night at the scene of a suspected major crime; he looked at the police activity, became startled, and immediately fled. This evasive conduct, coupled with his flimsy excuse to the cab driver, created a reasonable suspicion of his involvement. The subsequent 25-minute detention was a permissible investigatory stop, not an arrest, because officers were diligently pursuing their investigation by checking Willis's story at the nearby motel. By the time a de facto arrest occurred at the motel, the officers had developed probable cause based on the additional information linking Willis to the plane's pilot and his admission of knowing the other suspects.
Analysis:
This case provides a clear judicial roadmap for the application of the tiered framework for police-citizen encounters established in Terry v. Ohio. It reinforces that 'flight' or evasive conduct upon seeing law enforcement is a powerful factor in establishing reasonable suspicion for an investigatory stop. The decision also affirms the 'collective knowledge' doctrine, allowing the aggregation of information among officers to justify a stop or arrest. Furthermore, it clarifies that the line between a permissible extended investigatory stop and a de facto arrest hinges on the diligence and purpose of the police investigation, not merely the passage of a specific amount of time.
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