United States v. Huerta (Lack of Reasonable Suspicion for Terry Frisk)

United States v. Huerta
U.S. Court of Appeals for the Tenth Circuit
25-1050
October 29, 2025

In this case, police in Denver were investigating a shooting that occurred early in the morning. They identified a suspect described as a light-skinned Black male with a bald head, thick beard, and muscular build, and circulated a photo of him. Later that day, officers surveilled a vehicle believed to be connected to the suspect. When a group, including a Black male with some similar clothing but not matching the suspect’s physical description, arrived in a different car and then left in a third vehicle, officers decided to stop that vehicle at a gas station. During the stop, officers detained Noah Huerta, a passenger, and conducted a pat down, finding a firearm magazine on him. A subsequent search of the vehicle, after obtaining the driver’s consent, revealed a handgun near Huerta’s seat.

The United States District Court for the District of Colorado denied Huerta’s motion to suppress the evidence, finding that the officers had reasonable suspicion to believe he was armed and dangerous, and also ruled that the firearm would have been inevitably discovered

On appeal, the United States Court of Appeals for the Tenth Circuit held that the officers lacked reasonable suspicion to believe Huerta was armed and dangerous, as the connection between the group and the shooting suspect was tenuous and based on a mere hunch, and the conduct of the vehicle’s occupants was innocuous. The court also found that the inevitable discovery doctrine did not apply. The court reversed the denial of the motion to suppress and remanded for further proceedings.