4th Amendment-Sufficiency of Evidence

7^th Circuit Court of Appeals

Case Name: United States of America v. Deangelo Banks

Case No.: 24-2227

Officials: Ripple, Lee, and Pryor, Circuit Judges.

Focus: 4^th Amendment-Sufficiency of Evidence

Banks was pulled over by a police officer who observed him failing to activate a turn signal at least 100 feet before making a left turn, as required by Illinois law. Officers requested Banks’ driver’s license and proof of insurance. When he produced an expired insurance card, Banks exited the vehicle to contact someone for updated insurance information. While the stop was still in progress, another officer arrived with a trained narcotics detection dog, which alerted to the presence of drugs outside the vehicle. Officers searched the car and discovered a handgun concealed in the center console, although no narcotics were found. Banks was subsequently arrested and charged with being a felon in possession of a firearm.

The Central District of Illinois denied Banks’ motion to suppress the firearm, concluding that the officer’s testimony established reasonable suspicion for the traffic stop, the stop was not unlawfully prolonged, and the drug-detection dog’s alert supplied probable cause to search the vehicle. The court also denied Banks’ motion for a judgment of acquittal, finding the evidence sufficient for a reasonable jury to convict him. After the jury returned a guilty verdict, the district court denied his motion for a new trial.

The Seventh Circuit found that the district court did not clearly err in crediting the officer’s testimony regarding the traffic violation, that the duration of the stop remained constitutionally reasonable, and that the canine alert provided probable cause to search the vehicle. The court further concluded that the evidence presented at trial was sufficient to establish the defendant’s knowing possession of the firearm despite his status as a convicted felon.

Affirmed.

Decided 06/30/26

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