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11th Circuit Upholds Felon's Gun Conviction After Traffic Stop Challenge

The U.S. Court of Appeals for the Eleventh Circuit affirmed D'eante Corker's conviction for possession of a firearm as a convicted felon, rejecting his argument that police unlawfully prolonged a traffic stop for a canine search. The January 8, 2026 decision upholds the district court's denial of Corker's motion to suppress evidence.

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Seal of the Eleventh Circuit Court of Appeals

Case Information

Case No.:
25-10642

Key Takeaways

  • Eleventh Circuit affirmed D'eante Corker's felon-in-possession firearms conviction
  • Court rejected argument that traffic stop was unlawfully prolonged for canine search
  • District court's denial of suppression motion upheld under clear error standard

The U.S. Court of Appeals for the Eleventh Circuit affirmed D'eante Corker's conviction for possession of a firearm as a convicted felon, rejecting his constitutional challenge to the traffic stop that led to the discovery of incriminating evidence.

In a per curiam opinion filed January 8, 2026, the three-judge panel upheld the U.S. District Court for the Middle District of Florida's denial of Corker's motion to suppress evidence obtained during a vehicle search following a traffic stop.

Corker argued that police unlawfully prolonged the traffic stop to conduct a canine sniff that ultimately led to the discovery of evidence supporting his conviction. The defendant contended that the extended detention violated his Fourth Amendment rights against unreasonable searches and seizures.

The case centers on the constitutional limits of traffic stops and the circumstances under which law enforcement may extend such stops beyond their original purpose. Under established precedent, police may conduct brief investigative detentions during traffic stops, but any prolongation beyond the time reasonably required to complete the stop's mission must be supported by reasonable suspicion of additional criminal activity.

The Eleventh Circuit panel, composed of Circuit Judges Jill Pryor, Branch, and Grant, applied the standard review framework for suppression motions. The court reviewed the district court's factual findings for clear error while examining legal conclusions de novo, meaning the appeals court reviewed legal interpretations without deference to the lower court's analysis.

In suppression cases, appellate courts construe facts in the light most favorable to the prevailing party below - in this case, the government. The panel cited United States v. Newsome, a 2007 Eleventh Circuit precedent establishing that factual findings are clearly erroneous only when, based on all evidence, the reviewing court is "left with the definite and firm conviction that a mistake has been committed."

The district court had originally found that the traffic stop and subsequent search were constitutionally permissible, rejecting Corker's arguments that law enforcement exceeded the scope and duration allowed under the Fourth Amendment. The trial court's analysis would have examined factors including the length of the stop, the officer's stated reasons for the detention, and whether the canine deployment was reasonably related to the stop's original purpose.

Corker's conviction stems from federal charges under 18 U.S.C. § 922(g)(1), which prohibits persons previously convicted of felonies from possessing firearms or ammunition. This statute carries significant penalties and is frequently prosecuted in federal courts as part of efforts to combat gun violence and recidivism.

The case highlights ongoing tensions in Fourth Amendment jurisprudence regarding the permissible scope of traffic stops. The Supreme Court's decision in Rodriguez v. United States (2015) established that police may not prolong traffic stops to conduct dog sniffs without reasonable suspicion, but lower courts continue to grapple with applying this standard to specific factual scenarios.

Factors typically considered in determining whether a traffic stop was unlawfully prolonged include the duration of the stop, whether the canine unit was already present or had to be summoned, the officer's stated justifications for extending the detention, and whether the defendant's behavior or other circumstances provided reasonable suspicion of additional criminal activity.

The Eleventh Circuit's affirmance suggests that the evidence supported the district court's conclusion that the stop was conducted within constitutional parameters. The appeals court found no clear error in the trial court's factual determinations and agreed with its legal conclusions regarding the suppression motion.

This decision adds to the body of Eleventh Circuit precedent governing traffic stops and canine searches, providing guidance for law enforcement and defense attorneys in the circuit's jurisdiction, which includes Alabama, Florida, and Georgia.

The opinion was designated "Not for Publication," meaning it will not be included in the Federal Reporter series, though it remains available in electronic databases and may be cited as persuasive authority in future cases.

For Corker, the affirmance means his conviction stands, and his challenge to the evidence that formed the basis of his prosecution has been rejected at both the district and circuit levels. The defendant could potentially seek review by the Supreme Court through a petition for certiorari, though the high court accepts only a small percentage of such requests.

The case underscores the high burden defendants face when challenging the admissibility of evidence obtained during traffic stops, particularly when challenging factual determinations made by district courts that had the opportunity to assess witness credibility and evaluate evidence firsthand.

Topics

firearm possessionconvicted felonmotion to suppresstraffic stopFourth Amendmentcanine search

Original Source: courtlistener

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