US v. Watson: Prentiss Watson worked at a convenience store in downtown Baltimore, downstairs in the same building where he rented a room. In February 2010, detectives conducting surveillance on the building observed some other individuals engaging in drug transactions near the building on Tivoly Avenue, and arrested them. One of these individuals, Anthony Jackson, the police had observed entering and exiting the building where Prentiss worked, during the course of a drug transaction. Additionally, officers had reason to believe Mr. Jackson was carrying a gun at the time of this transaction. After arresting Jackson, police obtained a search warrant for the entire building. Officers entered the building to secure it and all individuals inside, including Mr. Watson. The detention of Mr. Watson and Keta Steele, owner of the store, neither of whom had been observed engaging in the drug transactions, lasted over three hours, and they were forced to remain in a back area of the store while police obtained their warrant. Upon execution of the warrant, a revolver and some ammunition was found on the same floor as Mr. Watson’s room, but in a separate area from Mr. Watson’s room and belongings. Police questioned Mr. Watson about the revolver, and he made the incriminating statement, "that old thing, it doesn’t even work."
The government charged Mr. Watson with being a felon in possession of a firearm and ammunition. Mr. Watson moved to suppress his statement on Fourth Amendment grounds and failed in his efforts. Mr. Watson went to trial and a jury convicted him on both counts. On appeal, the Fourth Circuit vacated Mr. Watson’s conviction, finding that on the unique facts presented here, that the police seizure of Mr. Watson violated his Fourth Amendment rights. In conducting its reasonableness review, the Fourth Circuit ultimately determined that the seizure was illegal, and Mr. Watson’s incriminating statement should have been suppressed. The government conceded that Mr. Watson was "seized," and that there was no probable cause to detain him. The Fourth Circuit considered the governmental objectives, i.e. preserving evidence and officer safety, and the Fourth Circuit determined that neither interest was implicated here to justify the unlawful custodial arrest that occurred. The length of the detention here seemed downplayed as a basis for finding the seizure illegal; rather, the fact that there was no probable cause for the detention, and no link between Mr. Watson and the criminal activity observed by the police that aided Mr. Watson in his appeal.