Quarles v. United States

Summary

The District of Columbia Court of Appeals vacated Marc Anthony Quarles's weapon convictions, holding that police lacked reasonable, articulable suspicion to stop him. The court announced that, in light of Heller, Bruen, and subsequent legislative changes, the mere possession of a handgun, without more, no longer supports an investigative stop because possession can no longer be treated as presumptively unlawful. Quarles's flight was given significantly reduced weight because he ran only after officers followed him, closed in, and repeatedly called out to him, making flight to avoid police interaction a plausible innocent response. With no other suspicious circumstances, the totality did not establish reasonable suspicion, requiring suppression of the recovered gun and vacatur of the convictions.