e-Journal Summary

e-Journal Number : 86510
Opinion Date : 09/11/2026
e-Journal Date : 09/23/2026
Court : Michigan Court of Appeals
Case Name : People v. Gamble
Practice Area(s) : Criminal Law
Judge(s) : Per Curiam – Wallace, Cameron, and Korobkin
Full PDF Opinion
Issues:

Search & seizure; Motion to suppress; Particularized reasonable suspicion for a stop under Terry v Ohio; People v Pagano; People v Prude; Illinois v Wardlow; Collective knowledge; People v Nguyen; Pat-down search; People v Custer

Summary

The court held that the trial court properly denied defendant’s motion to suppress because (1) the officer who stopped him had reasonable suspicion to do so, (2) the decision to perform a pat-down search of his person was justified, and (3) the use of handcuffs was warranted under the circumstances. The court first concluded that the totality of the circumstances known by a police sergeant (B) and an officer (M) at the time of defendant’s seizure supported “the existence of an ‘objectively reasonable particularized suspicion’ that [he] was ‘engaged in, or about to be engaged in, criminal activity.’” While his presence in the high crime area, or his refusal to listen to M or answer questions, by themselves, were not sufficient, additional factors supported his detention. A shooting was reported to have occurred in the area of the laundromat where he was seen moving about in the dark and scanning the street and parking lot. B “was justified in recognizing the ‘relevant characteristics’ of the laundromat, including its reputation for being a problematic hangout in a high crime area and reportedly being the location of the shootings less than an hour earlier, in determining whether the totality of the circumstances of defendant’s apparent lookout presence at the” laundromat’s corner entrance “was ‘sufficiently suspicious to warrant further investigation.’” Before stopping defendant, M was told that the shooting had occurred “near the laundromat and that defendant was the only individual seen near” it during B’s drive-by and observation from across the street. B “testified that he radioed his observations of the phone flashlight inside the dark, defunct laundromat and defendant exhibiting” lookout behavior to other officers, and M “testified that he received and was acting on [B’s] relayed observations.” The court held that “it was reasonable for [M] to suspect that defendant was involved in criminal activity on the basis of this collective knowledge, and he had reasonable suspicion to stop [him] to investigate the shooting allegations and his related suspicious behavior.” It also held that “the use of handcuffs to detain and separate defendant from” the shooting-related chaos “until the Terry stop and pat down could safely occur, was warranted.” Affirmed.

Full PDF Opinion