United States v. Michael Brandon

• Court: Court of Appeals for the Fourth Circuit
• Decided: February 20, 2026
• Docket: 24-4422
• Status: Unpublished

Opinion

USCA4 Appeal: 24-4422 Doc: 51 Filed: 02/20/2026 Pg: 1 of 5

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-4422

UNITED STATES OF AMERICA,

Plaintiff – Appellee,

v.

MICHAEL BRANDON,

Defendant – Appellant.

Appeal from the United States District Court for the District of Maryland, at Baltimore. Ellen Lipton Hollander, Senior District Judge. (1:22-cr-00239-ELH-1)

Argued: December 11, 2025 Decided: February 20, 2026

Before WILKINSON, AGEE, and THACKER, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ARGUED: Cullen Oakes Macbeth, OFFICE OF THE FEDERAL PUBLIC DEFENDER, Greenbelt, Maryland, for Appellant. David Christian Bornstein, OFFICE OF THE UNITED STATES ATTORNEY, Baltimore, Maryland, for Appellee. ON BRIEF: James Wyda, Federal Public Defender, OFFICE OF THE FEDERAL PUBLIC DEFENDER, for Appellant. Erek L. Barron, United States Attorney, Brandon K. Moore, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Baltimore, Maryland, for Appellee.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 24-4422 Doc: 51 Filed: 02/20/2026 Pg: 2 of 5

PER CURIAM:

Michael Brandon appeals his conviction, entered pursuant to a conditional guilty

plea, for possession of a firearm in furtherance of a drug trafficking crime in violation of

18 U.S.C. § 924(c)(1)(A). On appeal, Brandon challenges the district court’s denial of his

motion to suppress the evidence seized from his vehicle following an investigative stop.

For the following reasons, we affirm.

While on patrol, Detective Kaivon Stewart of the Baltimore City Police Department

identified a vehicle, which Brandon was driving, that he believed violated Maryland’s

window tint statute, Md. Code Ann., Transp. § 22-406(i). Stewart pulled behind the

vehicle, recognized that it bore a Pennsylvania dealer’s plate, and initiated a traffic stop.

After a series of events, including a physical struggle, Brandon attempted to avoid arrest

by briefly dragging Stewart with his vehicle until it wrecked into a nearby pole. At that

point, Stewart, with the assistance of responding officers, restrained Brandon and seized a

firearm with an extended magazine from Brandon’s waistband, along with various drugs

from inside the vehicle.

Brandon moved to suppress the evidence, arguing that, under this Court’s decision

in United States v. Johnson, 256 F.3d 214 (4th Cir. 2001), Stewart did not have reasonable

suspicion to initiate the traffic stop. The district court denied the motion, concluding that

Stewart had reasonable suspicion and, even if he did not: (1) the good-faith exception for

relying on “binding appellate precedent” applied given the Maryland Court of Special

Appeals decision in Baez v. Maryland, 192 A.3d 945 (Md. Ct. Spec. App. 2018); and (2)

Brandon’s subsequent illegal conduct—the physical struggle and flight—vitiated any taint.

2 USCA4 Appeal: 24-4422 Doc: 51 Filed: 02/20/2026 Pg: 3 of 5

United States v. Brandon, No. ELH-22-0239, 2023 WL 6961937, at *21–25, *31–33 (D.

Md. Oct. 19, 2023). Brandon then entered a conditional guilty plea, expressly reserving his

right to appeal the district court’s denial of his motion to suppress and he now appeals.

Even assuming Stewart lacked reasonable suspicion, we conclude that the good-faith

exception to the exclusionary rule applies and therefore affirm the district court’s decision.

“When, as here, a district court denies a motion to suppress, we review the court’s

legal conclusions de novo and its factual findings for clear error, considering the evidence

in the light most favorable to the government.” United States v. Turner, 122 F.4th 511, 516

(4th Cir. 2024), cert. denied, 145 S. Ct. 1894 (2025) (cleaned up).

The Fourth Amendment provides: “The right of the people to be secure in their

persons, houses, papers, and effects, against unreasonable searches and seizures, shall not

be violated.” U.S. Const. amend. IV. In order “to safeguard against future violations of

Fourth Amendment rights through the rule's general deterrent effect,” Arizona v. Evans,

514 U.S. 1, 10 (1995), the exclusionary rule prevents the government from using illegally

obtained evidence against the victim of an illegal search, see Davis v. United States, 564

U.S. 229, 231–32 (2011). However, “exclusion of evidence has ‘always been [the] last

resort, not [the] first impulse,’” United States v. Stephens, 764 F.3d 327, 335 (4th Cir. 2014)

(alterations in original) (quoting Hudson v. Michigan, 547 U.S. 586, 591 (2006)), because

it creates “substantial social costs,” United States v. Leon, 468 U.S. 897, 907 (1984).

In that vein, the exclusionary rule is subject to exceptions, including the good-faith

doctrine. Davis, 564 U.S. at 232, 238–40. Because “[t]he [exclusionary] rule’s sole purpose

. . . is to deter future Fourth Amendment violations,” id. at 236–37, in order “[t]o trigger

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the exclusionary rule, police conduct must be sufficiently deliberate that exclusion can

meaningfully deter it, and sufficiently culpable that such deterrence is worth the price paid

by the justice system[,]” Herring v. United States, 555 U.S. 135, 144 (2009). “[W]hen the

police act with an objectively reasonable good-faith belief that their conduct is lawful, or

when their conduct involves only simple, isolated negligence, the deterrence rationale loses

much of its force, and exclusion cannot pay its way.” Davis, 564 U.S. at 238 (cleaned up).

Law enforcement action taken “in objectively reasonable reliance on binding appellate

precedent” at the time of the search or seizure is protected by the good-faith doctrine

because suppressing evidence obtained from a search or seizure previously approved by

precedent would “do nothing to deter police misconduct . . . [and] would come at a high

cost to both the truth and public safety[.]” Id. at 232.

We agree with the district court that, regardless of whether Stewart had reasonable

suspicion, the good-faith exception under Davis applies, thus foreclosing the application

of the exclusionary rule. That is, Stewart acted in “objectively reasonable reliance on

binding appellate precedent[.]” Davis, 564 U.S. at 249–50. The Maryland Court of Special

Appeals held in Baez that “[a] police officer, suspecting a tint window violation, may

lawfully stop a vehicle to investigate further and ask to see the vehicle registration to

determine origin of registration. That the vehicle may be registered in a foreign jurisdiction

does not vitiate the lawfulness of the stop.” 1 192 A.3d at 951.

1 As a reported decision from the Maryland Court of Special Appeals, Baez “constitutes binding precedent.” Johnson v. Maryland, 115 A.3d 668, 683 n.5 (Md. Ct. Spec. App. 2015). 4 USCA4 Appeal: 24-4422 Doc: 51 Filed: 02/20/2026 Pg: 5 of 5

That is precisely what occurred here. Stewart identified Brandon’s vehicle while on

patrol and, using his training and experience, concluded that the vehicle’s tint “was so dark

that it did not comply with Maryland law.” Brandon, 2023 WL 6961937, at *17. At that

point, Baez permitted him to stop the vehicle to determine its place of registration. We

therefore conclude that the good-faith exception to the exclusionary rule applies and bars

suppression of any evidence tainted by any constitutional defect in the search of the vehicle

after the traffic stop. 2

Accordingly, we affirm the district court’s order denying Brandon’s motion to

suppress.

AFFIRMED

2 In addition, for the reasons stated by the district court, we conclude that Brandon’s intervening illegal conduct vitiates any potential illegality of the traffic stop and renders the seized evidence admissible. See Brandon, 2023 WL 6961937, at *31–33. 5