Background
John Robert Williams, III was convicted of possessing a firearm and ammunition as a felon in violation of 18 U.S.C. § 922(g)(1). Before trial, he moved to suppress evidence and to dismiss the indictment. The district court denied both motions.
On appeal, Williams argued that § 922(g)(1) violated the Second Amendment as applied to him. He also challenged the investigative stop and warrantless search of his vehicle and contended that the federal indictment violated the Speedy Trial Act because it was filed more than 30 days after his arrest on state charges.
The Court’s Holding
The Fourth Circuit affirmed in an unpublished per curiam opinion. It held that Williams’ as-applied Second Amendment challenge was foreclosed by United States v. Hunt, 123 F.4th 697 (4th Cir. 2024), cert. denied, 145 S. Ct. 2756 (2025).
The court also upheld the denial of suppression. The officer had reasonable suspicion based on the nighttime encounter in a high-crime area, the vehicle’s match to one recently suspected in drug activity, and Williams’ act of tossing a blue bag into the vehicle after seeing the officer. The officer permissibly illuminated the vehicle’s interior with a flashlight, and the suspected narcotics and scale visible inside supplied probable cause for a warrantless automobile search.
Finally, the court held that the Speedy Trial Act’s 30-day indictment clock did not begin with Williams’ state arrest. The district court did not clearly err in finding that Williams remained in state custody to answer pending state charges, rather than being held solely for federal prosecution, when the federal indictment was filed.
Key Takeaways
- Fourth Circuit precedent foreclosed Williams’ as-applied Second Amendment challenge to § 922(g)(1).
- An officer’s observations before the stop established reasonable suspicion, while suspected narcotics and a scale seen in plain view established probable cause to search the vehicle.
- A state arrest does not start the Speedy Trial Act clock when valid state charges remain pending and the defendant is not being held solely to answer federal charges.
Why It Matters
The decision applies existing Fourth Circuit doctrine to three recurring criminal-defense issues: constitutional challenges to the federal felon-in-possession statute, vehicle searches following investigative stops, and the point at which state detention can trigger the federal Speedy Trial Act.
Although unpublished and nonprecedential, the opinion illustrates the factual showing that can support reasonable suspicion and an automobile search, as well as the importance of whether state proceedings remained genuine and active when a later federal prosecution began.