Damion Hallmon was convicted by a jury of being a felon in possession of ammunition in violation of federal law. The case began on August 28, 2022, when a Bloomington, Minnesota police officer stopped Hallmon's vehicle after observing a suspended object obstructing the driver's view and discovering the registered owner had a suspended license. During the stop, the officer found a bag of marijuana on the floorboard and, after Hallmon admitted to its presence, searched the vehicle. The search revealed a loaded pistol in a handbag. Hallmon told the officer he was 'taking the fall' for the firearm. Hallmon was subsequently indicted and sentenced to 74 months in prison. On appeal, he challenged the legality of the stop and search, the admission of evidence, and the constitutionality of the underlying statute.
The Eighth Circuit addressed six main arguments raised by Hallmon. First, regarding the Fourth Amendment, the court held the traffic stop was lawful because the officer had probable cause to stop the vehicle for a traffic violation. The court further found the stop was not unreasonably extended, as the officer's observations of Hallmon's nervousness and physical signs of drug use provided reasonable suspicion to continue the investigation. The search of the vehicle was justified by probable cause, stemming from the officer's observation of the marijuana bag and Hallmon's admission that there was more marijuana in the ashtray. Second, the court rejected Hallmon's claim that he was in custody during his initial statements. Applying the totality of the circumstances, the court found that Hallmon was not restrained to the degree associated with a formal arrest, as he was not handcuffed or placed in a patrol car, and the atmosphere was not police-dominated. Third, the court found the evidence sufficient to prove the ammunition traveled in interstate commerce, relying on expert testimony that the ammunition was manufactured outside of Minnesota. Fourth, the court upheld the exclusion of recorded jail calls between Hallmon and his fiancée. The court determined the calls were inadmissible hearsay that did not fit the 'present state of mind' exception because they discussed past events, and they lacked the necessary guarantees of trustworthiness for the residual exception. Fifth, the court affirmed the two-level obstruction of justice enhancement. The district court found by a preponderance of the evidence that Hallmon attempted to influence a witness to accept responsibility for the crime and committed perjury during his trial testimony regarding the meaning of the word 'burner.' Finally, the court rejected Hallmon's Second Amendment challenge, noting that Eighth Circuit precedent already forecloses such arguments against felon possession charges.
Hallmon's 74-month sentence and three years of supervised release remain in effect. The decision reinforces the Eighth Circuit's standard that a traffic stop can be extended if officers develop reasonable suspicion of additional criminal activity during the encounter. It also clarifies that statements made during a traffic stop are generally not considered custodial for Miranda purposes unless the suspect is effectively under arrest. The ruling leaves open the question of whether a defendant's due process rights are violated when hearsay evidence is excluded, confirming that such exclusions are permissible under the Federal Rules of Evidence unless they violate specific constitutional protections not present in this case.
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