Williams was arrested in April 2023 after Metropolitan Police Department investigators patrolling Southeast D.C. approached his parked car with its headlights on. The encounter escalated when Investigator Wilfredo Guzman, using his flashlight, observed a suspicious bulge near Williams's groin that led him to believe Williams was armed. When Guzman asked to 'make sure' the object wasn't a gun, Williams told the officer not to touch him and fled, leading to his apprehension and the discovery of a firearm in his pants.
Writing for a three-judge panel, Associate Judge Shanker held that the officers had reasonable articulable suspicion to seize Williams under Terry v. Ohio. As Shanker explained, Investigator Guzman 'literally believed that [Williams] was in possession of a firearm' because the bulge resembled the 'receiver' or 'slide' of a gun and was too 'thin' to be a cell phone. The court found this testimony was 'explicitly based on his experience in recovering multiple firearms' and his specialized training as a police officer.
The court rejected Williams's argument that the rectangular object alone couldn't justify reasonable suspicion, noting that 'there is more than a bulge to inform the court's examination.' Judge Shanker emphasized that Guzman 'provided details about the shape and size of the bulge he observed on Williams, including that it was thin and rectangular and looked like a part of a firearm,' distinguishing the case from situations involving 'generic bulges' that could have innocent explanations.
Williams had moved to suppress all evidence before trial, arguing that police seized him without reasonable suspicion when they approached his vehicle in the apartment complex parking lot. The Superior Court's trial judge, Hon. Errol R. Arthur, denied the motion after finding Investigator Guzman to be a credible witness whose testimony was 'entirely consistent with the body camera footage.' The trial court determined Williams was seized when Guzman placed his hands on Williams's car and moved to frisk him.
The appellate court also considered Williams's 'blading' behavior—turning his body away from officers—and recent gun violence in the area. Guzman testified there had been 'a few shootings' within the same week in the area surrounding 22nd Street Southeast, and that officers were specifically patrolling in response to this activity. The court found this locational evidence provided 'some useful context' for Guzman's observations, though it rejected the government's argument about Williams's alleged nervousness, noting that 'it is common for most people to exhibit signs of nervousness when confronted by a law enforcement officer.'
In a significant development, the government moved to vacate Williams's conviction for possession of a large-capacity ammunition feeding device, stating it believes that statute is unconstitutional. The court granted the unopposed motion and vacated that conviction, referencing its recent decision in Benson v. United States that struck down D.C.'s high-capacity magazine ban. Williams did not challenge the constitutionality of the statute himself.
The ruling affirms Williams's convictions for unlawful possession of a firearm with a prior conviction, carrying a pistol without a license, possession of an unregistered firearm, and unlawful possession of ammunition. Williams was sentenced to 18 months in prison followed by three years of supervised release. The decision provides guidance on when police observations of suspicious bulges can support reasonable suspicion, particularly when officers can articulate specific details about the object's characteristics.