Opinion — United States v. Johnson (Dkt. 57, C.D. Ill.)

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An opinion of U.S. District Judge Colleen R. Lawless in United States v. Eric Johnson, Case No. 23-cr-30023, in the U.S. District Court for the Central District of Illinois, entered July 9, 2026 as Doc. 57. It denies the defendant's Motion to Suppress Evidence (Doc. 35) and Amended Motion to Suppress (Doc. 45) after evidentiary hearings. The defendant, charged by indictment with possession with intent to distribute marijuana and two firearm counts, argued that the traffic stop for failing to come to a complete stop in a private parking lot was unlawful, that he was detained for more than ten minutes without reasonable suspicion, that Officer Riebeling arrested him without probable cause, and that the vehicle search was illegal. Crediting the officers' testimony, the court finds the traffic stop valid and the detention and arrest lawful.

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3:23-cr-30023-CRL #57 _ Filed: 07/09/26        Pagel1of8
                                                                                   E-FILED
                                                            Thursday, 09 July, 2026 04:40:43 PM
                                                                  Clerk, U.S. District Court, ILCD

                   IN THE UNITED STATES DISTRICT COURT
                   FOR THE CENTRAL DISTRICT OF ILLINOIS
                            SPRINGFIELD DIVISION

 UNITED STATES OF AMERICA,            )
       Plaintiff,                     )
                                      )
  v.                                  )       Case No. 23-cr-30023
                                      )
                                      )
 ERIC JOHNSON,                        )
       Defendant.                     )

                                    OPINION

 COLLEEN R. LAWLESS, United States District Judge:

       Before the Court are Defendant Eric Johnson’s Motion to Suppress Evidence (Doc.

 35) and Amended Motion to Suppress (Doc. 45). The Court has considered the evidence

presented during the evidentiary hearings along with the parties’ briefs. For the reasons

that follow, Defendant’s motions are denied.

I.     BACKGROUND

       Defendant is charged by Indictment with one count of possession with intent to

distribute marijuana, one count of possessing a firearm during and in furtherance of a

drug trafficking crime, and one count of possessing a firearm as a convicted felon

Defendant argues the following bases in support of his motion to suppress: 1) he was

subjected to an unlawful traffic stop when he was cited for failing to come to a complete

stop in a private parking lot; 2) he was unlawfully detained for more than ten minutes

when the officer did not advance the alleged purpose of the traffic stop and there was no

reasonable suspicion of criminal activity; 3) he was subjected to an illegal arrest without

probable cause when Officer Riebeling “attempted to handcuff him —without warning

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and for no apparent reason” before being arrested for resisting and/or obstructing by
trying to flee the car; and 4) the search of his vehicle was illegal as it was conducted
without a warrant, consent, or any applicable exception to the warrant requirement. The
Government contends the traffic stop was lawful because Defendant did not come to a
complete stop before exiting the parking lot and Officer Riebeling developed
independent reasonable articulable suspicion of criminal activity when Defendant
became argumentative and attempted to exit the police vehicle. Upon his arrest,
Defendant's vehicle was towed, searched pursuant to policy, and evidence was seized by
officers.

The motion hearing was held over the course of three days. Following the first
hearing, Defendant obtained leave to file an Amended Motion to Suppress “to more fully
plead his position that Officer Riebling’s basis for this traffic stop, according to his
testimony on February 25, 2026, and the Government's arguments, is still not a lawful
basis for a traffic stop, as it is still a purported violation of the Ilinois Rules of the Road
(625 ILCS 5/11-100 et seq.) which is not applicable to private roads or other property.”
(Doc. 44). On May 14, 2026, the Government filed a Supplemental Response (Doc. 54) to
Defendant’s Amended Motion to Suppress.

II. DISCUSSION

A. Legality of Traffic Stop

Defendant first argued the traffic stop was illegal because it was based on an
alleged stop sign violation occurring on private property, which he claimed does not
provide a lawful basis for the stop under Ilinois law. The Government responded by

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stating Defendant was stopped for failing to yield or come to a complete stop when
entering a roadway from private property, that being the parking lot for a Walgreens
store located on East Clear Lake Avenue in Springfield, Illinois. At the hearing, Officer
Riebeling credibly testified Defendant did not come to a complete stop when exiting the
Walgreens lot onto Hill Street. In his Amended Motion to Suppress, Defendant alleges
Hill Street is a private road on private property and failing to stop when exiting a private
parking lot onto a private road is not an offense under Illinois law.

“Traffic stops are seizures, so they must be reasonable under the circumstances.”
Whren v. United States, 517 U.S. 806, 809 (1996). A police officer may stop a vehicle if the
officer has reasonable suspicion of a traffic violation. United States v. Cole, 21 F.4th 421,
427 (7th Cir. 2021). This applies even to minor traffic infractions. United States v. Jackson,
962 F.3d 353, 357 (7th Cir. 2020). The question is whether the officer reasonably believed
the driver committed a traffic violation, not whether the driver actually committed a
traffic violation. See Cole, 21 F.4th at 428; United States v. Stanbridge, 813 F.3d 1032, 1037
(7th Cir. 2016) (noting that “a police officer’s objectively reasonable mistake of law can
provide reasonable suspicion for a seizure”). “Even the reasonable belief that a driver
committed a minor traffic infraction will support a stop.” Jackson, 962 F.3d at 357. “The
government bears the burden of proving by a preponderance of the evidence that
reasonable suspicion supported the traffic stop.” Jackson, 962 F.3d at 357.

The testimony and evidence presented established that Hill Street was a public
roadway and thus subject to Illinois’ traffic laws. The Government has established by a
preponderance of the evidence that Officer Riebling had reasonable suspicion to stop

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Defendant for failing to yield when entering a roadway from private property —the
Walgreens parking lot— which is a violation under 625 ILCS 5/11-1205. See United States
v. Phillips, 2024 WL 3842092, at *3 (7th Cir. 2024), At the very least, it was clear based on
Officer Riebeling’s testimony that he reasonably believed Defendant committed a traffic
violation. Thus, the traffic stop of Defendant was lawful.

B. Length of Detention

Defendant next contends he was subject to prolonged detention when Officer
Riebeling detained him for over ten minutes without writing a ticket or warning or
otherwise advancing the purported basis of the traffic stop, all while lacking reasonable
suspicion of criminal activity. Defendant asserts this prolonged detention was not
justified by any new information or observations that would warrant further
investigation.

“[A] police stop exceeding the time needed to handle the matter for which the stop
was made violates the Constitution's shield against unreasonable seizures.” Rodriguez v.
United States, 575 U.S. 348, 350 (2015). A seizure justified only by a traffic violation
“become[s] unlawful if it is prolonged beyond the time reasonably required to
complete th[e] mission of issuing a ticket for the violation.” Id. at 350-51 (internal
quotation marks omitted). That mission may include “determining whether to issue a
traffic ticket” and pursuing “ordinary inquiries incident to the traffic stop,” such as
“checking the driver’s license, determining whether there are outstanding warrants

against the driver, and inspecting the automobile’s registration and proof of insurance.”

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Cole, 21 F.4th at 428. Questions about the driver's travel plans “ordinarily fall within the
mission of a traffic stop.” Id. at 429.

A stop can be prolonged, however, if an officer has developed a “reasonable
suspicion that criminal activity is afoot.” Matz v. Klotka, 769 F.3d 517, 522 (7th Cir. 2014).
Reasonable suspicion requires more than a “hunch” but “the likelihood of criminal
activity need not rise to the level required for probable cause, and it falls considerably
short of satisfying a preponderance of the evidence standard.” Cole, 21 F.4th at 433
(internal quotation marks omitted). “Whether a lawful stop extends so long that it raises
constitutional concerns turns on reasonableness.” United States v. Gholston, 1 F.Ath 492,
496 (7th Cir. 2021).

Upon conducting the traffic stop, Officer Riebeling asked Defendant to sit in the
front seat of Riebeling’s vehicle while he completed the mission of the traffic stop. Officer
Riebeling testified that it can take 12 to 16 minutes to conduct a traffic stop and write a
citation. He stated it typically takes longer when, as here, the driver is not from Illinois.
Officer Riebeling testified it is standard practice for him to ask travel plan questions as
part of a traffic stop. Defendant told the officer he moved from Texas to Michigan, and
he had just traveled from St. Louis where he dropped off some of his “girlfriend’s stuff”
or his girlfriend’s friend and was en route to Chicago before eventually returning to
Michigan. He stated he possibly was moving back to Texas because he and his girlfriend
had broken up but were trying to work things out. Defendant appeared increasingly
frustrated as the questions continued, particularly when Riebeling asked the name of his
girlfriend’s friend and later when he asked if there was any cannabis in the vehicle.

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Officer Riebeling reasonably believed Defendant’s answers to be inconsistent. After
asking Defendant if the vehicle contained anything illegal, Officer Riebeling informed
Defendant he was going to run his dog around the vehicle. It appeared Officer Riebeling
then retrieved his handcuffs, and Defendant opened the passenger door, where Officer
Grant Harding was waiting and Defendant did not make a further move to exit the
vehicle. Officer Riebeling testified that by opening the door, Defendant attempted to flee
the police vehicle and interfered with his ability to walk the dog around Defendant's
vehicle. The officers eventually deployed a taser and arrested Defendant for obstructing
the investigation. Defendant was sitting in the police vehicle for just under nine minutes
before Officer Riebeling initiated the arrest. This was approximately ten minutes after
Riebeling first made contact with Defendant at Defendant's vehicle.

It is apparent from the video that Defendant believed Officer Riebeling’s questions
far exceeded the scope of a violation for failure to yield or come to a complete stop when
entering a roadway from private property. However, the officers were entitled to conduct
“ordinary inquiries incident to the traffic stop” and ask about Defendant's travel plans.
Furthermore, a traffic stop of ten minutes to perform these tasks is not unreasonable. See
United States v. Lewis, 920 F.3d 483, 492-93 (7th Cir. 2019) (determining officer did not

unreasonably prolong the stop in issuing a warning about 10 minutes and 50 seconds

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after pulling the driver over). Thus, the Court concludes the traffic stop was not
unreasonably extended beyond its original mission.?

C. Illegal Arrest without Probable Cause and Search of Vehicle

Defendant next alleges he was arrested without probable cause when, after he
refused to consent to a search or dog sniff, Officer Riebeling attempted to handcuff him —
without warning and for no apparent reason. Upon protesting this, Defendant was told
he was under arrest for “resisting.” He was eventually tased and arrested. The video
shows that Defendant became increasingly combative with Officer Riebeling when
Riebeling told him he was going to conduct a K-9 sniff, repeatedly telling the officer it
was illegal. The Government contends Defendant tried to take his license and rental
paperwork from Officer Riebeling before attempting to exit the police vehicle. The video
appears to at least show Defendant gesturing with his hands in requesting the officer
return his license and documents. Then, Defendant opened the passenger door as Officer
Riebeling displayed handcuffs. Officer Harding testified this move by Defendant and the

possibility he might attempt to flee on foot gave rise to officer safety concerns. Based on

these circumstances, the Court concludes the officers had probable cause to arrest
Defendant for obstructing the investigation or attempting to flee. Furthermore, after

being told he was under arrest, Defendant then physically resisted arrest.

? The Court further finds that Officer Riebeling developed a reasonable articulable suspicion of
other criminal activity during that stop, given Defendant’s answers to travel-related questions
and Defendant's increased frustration at Riebeling’s questions.

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3:23-cr-30023-CRL #57 _ Filed: 07/09/26 Page 8of8

Defendant next contends the search of his vehicle was unlawful because his arrest
was illegal. Having determined Defendant's arrest was lawful, however, the Court
concludes the search of Defendant’s vehicle was a proper inventory search. See United
States v. Cartwright, 630 F.3d 610, 613 (7th Cir. 2010) (citing South Dakota v. Opperman, 428
U.S. 364, 376 (1976)) (noting that “[iJnventory searches constitute a well-recognized
exception to the warrant requirement and are reasonable under the Fourth Amendment”
and “local police departments routinely inventory and secure the contents of impounded
vehicles”).

Ill. CONCLUSION

Upon reviewing the record and considering the credible testimony of the officers,
the Court finds the traffic stop was valid and Defendant was not unlawfully detained
without reasonable suspicion or illegally arrested without probable cause. Therefore,
Defendant’s Motion to Suppress Evidence (Doc. 35) and Amended Motion to Suppress
Evidence (Doc. 45) are DENIED.

ENTER: July 9, 2026

/s/ Colleen R. Lawless
COLLEEN R. LAWLESS
UNITED STATES DISTRICT JUDGE

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