United States v. Toddrey Bruce (11th Cir. October 2020)

The Federal Docket

November 10, 2020

Fourth Amendment – Reasonable suspicion exists to stop an individual where officers receive a 911 call late at night indicating that there are individuals in a high-crime area that may be armed and dangerous, and one of the individuals flees upon being approached by officers.

Officers in Miami responded to a 911 call at 3:20 AM from an unnamed caller. The caller stated that men were arguing next a car in a high-crime area of Miami and that one of the men was armed and “might be shooting any minute now.” When the officers arrived and found two men sitting in a car, one fled. Toddrey Bruce was tackled by an officer while fleeing, and officers discovered a pistol on him. Bruce was convicted of being a felon in possession of a firearm.

On appeal, Bruce argued that the police lacked reasonable suspicion that he had engaged in criminal activity. The Eleventh Circuit disagreed, holding that “given the details of the 911 call, the time of day, and the high-crime area, the officers could reasonably suspect that Bruce had engaged in criminal activity.”

Appeal from the Southern District of Florida

Opinion by Grant, joined by Martin and Lagoa

Click here to read the opinion.

Tom Church - Tom is a trial and appellate lawyer focusing on criminal defense and civil trials. Tom is the author of "The Federal Docket" and is a contributor to Mercer Law Review's Annual Survey in the areas of federal sentencing guidelines and criminal law. Tom graduated with honors from the University of Georgia Law School where he served as a research assistant to the faculty in the areas of constitutional law and civil rights litigation. Read Tom's reviews on AVVO. Follow Tom on Linkedin.

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