When a “Voluntary Encounter” Becomes a Seizure: 4th Cir. Suppresses Gun After Officers Blocked Parked Car
United States v. Williams, No. 24-4512 (4th Cir. July 7, 2026) TL;DR Police received an anonymous 911 report that a light-skinned male with braids was sitting in a white Mercedes near an apartment-complex pool and “appears to be making drug transactions.” Two officers responded in separate marked police vehicles. The officers intended to make a voluntary encounter. But instead of parking in available spaces, they simultaneously stopped their patrol vehicles in the roadway, wi
9 min read
Words Are Not Resistance: Sixth Circuit Denies Qualified Immunity for Force Following Verbal Confrontation
Steger v. Willis, No. 25-6006 (6th Cir. July 21, 2026) TL;DR Police responded to a theft complaint and encountered the suspect standing behind an iron gate on his own front porch. The encounter became heated. The suspect refused to provide identification, told officers to get off his property, and ultimately yelled, “Fuck you!” at one of the officers. According to the plaintiff’s version of events—which the court was required to accept at the qualified-immunity stage—the offi
6 min read
Can a Suspect Retreat Into His Home to End a Terry Stop?
Hayat v. Diaz, No. 25-1235 (4th Cir. Aug. 20, 2026) TL;DR Police received a priority kidnapping call after an eyewitness reported seeing a man put three children into the trunk of a vehicle. Officers traced the vehicle to Fareed Hayat's home and approached him while he and his wife were outside. The encounter initially was consensual. But after officers questioned Hayat about the reported kidnapping, he refused to answer certain questions, prevented his wife from continuing t
11 min read