United States of America v. Stephen Duane Woods, Jr.

Grand Rapids, Michigan, criminal defense lawyer Michael Bartish represented the Defendant charged with felony possession of a firearm.

Once the officers successfully detained Woods, he told them multiple times that he didn’t
have anything on his person. One officer then patted Woods down but didn’t find a gun. Other officers used their flashlights to look through the windows of Woods’s locked car for the gun, but they didn’t see one either. So Blank used Woods’s keys to unlock the car and, after a brief search, the officers discovered a pistol under the front passenger seat

Woods moved to suppress the evidence. The motion was denied.

Since Woods had prior felony convictions, a grand jury charged him with possessing a
firearm as a felon. See 18 U.S.C. § 922(g)(1). He moved to suppress the gun, arguing that the officers’ warrantless search of his car violated the Fourth Amendment. The district court denied that motion. It concluded that the officers had probable cause to believe that evidence of a crime—the gun—was in Woods’s car, so they didn’t need a warrant before searching his vehicle.

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The Fourth Amendment protects citizens from “unreasonable searches” of their “effects.”
U.S. Const. amend. IV. Generally, this right requires law enforcement to obtain a warrant before conducting a search. But there are exceptions to the warrant requirement. As relevant here, the “automobile exception” allows warrantless searches of a car if officers have probable cause to believe it contains evidence of a crime. California v. Acevedo, 500 U.S. 565, 578–80 (1991); United States v. Simpson, 138 F.4th 438, 444 (6th Cir. 2025). So all officers need to search a car is probable cause that it holds evidence of a crime.

“Probable cause is not a high bar.” District of Columbia v. Wesby, 583 U.S. 48, 57
(2018) (cleaned up). To search a place, officers need only a “fair probability” that they will find evidence of a crime there. Illinois v. Gates, 462 U.S. 213, 238 (1983). Here, there was a fair probability that the gun was in Woods’s car, so the officers had probable cause to search it.

Woods pled guilty.

Affirmed