Michael Stoffer was in a common laundry room of a Pittsburgh apartment complex on January 29, 2025, when officers on patrol entered, spotted the firearm in his waistband, immediately approached him, seized the gun, handcuffed him, and questioned him. Stoffer told the officers he had no license for the gun. Allegheny County prosecutors charged him with felony possession and carrying a firearm without a license, and also with possession of a controlled substance based on drugs seized during the arrest. A state court suppressed the evidence, relying on Pennsylvania Supreme Court precedent holding that the officers lacked reasonable suspicion to detain Stoffer, and the district attorney dropped the charges. Federal prosecutors then indicted Stoffer on September 16, 2025, on a federal firearms charge under 18 U.S.C. 922(g)(1) based on the same incident.
United States District Judge J. Nicholas Ranjan granted Stoffer's suppression motion on April 22, 2026, holding that the stop violated the Fourth Amendment. All parties agreed on the governing legal principle: carrying a firearm alone, in a state that authorizes concealed carry, cannot give rise to reasonable suspicion. The court grounded that conclusion in long-standing Third Circuit precedent, citing United States v. Ubiles, 224 F.3d 213 (3d Cir. 2000), which reversed a denial of a suppression motion where police stopped a defendant based only on an anonymous tip and his possession of a firearm in the Virgin Islands, where firearm possession carries no presumption of illegality, and United States v. Lewis, 672 F.3d 232 (3d Cir. 2012), which affirmed a grant of suppression because possession of a firearm in the Virgin Islands, in and of itself, does not provide officers with reasonable suspicion.
The government argued that additional circumstances pushed the encounter past the reasonable-suspicion threshold: it was approximately 11:30 p.m., Stoffer was not doing laundry, the gun was protruding from his sweatpants, the complex was high-crime, and officers had been told that laundry rooms were locked and off-limits due to drug use, robberies, and trespassers. Judge Ranjan rejected each of those factual premises after an evidentiary hearing that included body camera footage and witness testimony.
The court found that a laundry machine in the room visibly had time remaining on its cycle, that Stoffer made no threatening or furtive movements, that the officers were not at risk of harm and did not subjectively or objectively believe they were, and that the manner in which Stoffer carried the gun in his waistband did not materially change the analysis. On the locked-laundry-room claim, the court found the officers' testimony vague and not entirely credible, noting that testimony from residents established the laundry rooms were not locked, including the specific room where Stoffer was arrested. The court also declined to give significant weight to the high-crime character of the neighborhood, observing that officers cannot simply stop and frisk anyone who might have a gun in a high-crime area absent something more suspicious.
The court suppressed the gun and all statements Stoffer made to police after the stop.