UNITED STATES OF AMERICA v. EZEKIEL DONJA GARDNER
US Court of Appeals for the Fourth Circuit, Keenan, May 18, 2016
Miranda – Unhandcuffed suspect removed from vehicle was not under “de facto arrest” requiring Miranda when officers told him that they had received information that he had a firearm and asked him whether he had “anything illegal.”

Nothing particularly remarkable in this opinion.

Stop was legal based on corroborated information from reliable informant (also suspect’s ex-girlfriend)
Search was legal based on information + suspect’s admission + furtive movement to hide gun when police conducted traffic stop

As the detective and his lieutenant exited the patrol car to approach the driver, the police chief “remained in the squad car to request
assistance.”