“The Watson Rule”: Visible Contraband & Identity Refusal as Independent Sources of Probable Cause under the Fourth Amendment

Introduction

United States v. Watson, No. 24-3679 (6th Cir. July 9, 2025) presented the Court of Appeals for the Sixth Circuit with a familiar but fact-dense Fourth Amendment challenge. Defendant-appellant Jtton Edward Watson (also known as “J’ttonAli One Eye El Bey”) was stopped while driving with a suspended license, arrested after refusing to identify himself, and later convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm found inside a locked box in his vehicle. He sought suppression of all physical evidence, arguing lack of probable cause for the stop, arrest, and subsequent warrantless vehicle search.

The Sixth Circuit affirmed the district court’s denial of suppression and sustained the conviction, but in doing so it crystallised two principles that will likely reverberate in future Fourth Amendment litigation:

1. Visible, non-medical marijuana inside a vehicle—identified through an officer’s training and experience—creates probable cause to search the entire vehicle (including locked containers) under the automobile exception.
2. A motorist’s refusal to produce a driver’s licence after an officer already has articulable reason to believe the licence is suspended constitutes independent probable cause for arrest, irrespective of whether the underlying traffic offence itself is arrestable under state law.

These two holdings—collectively dubbed here the “Watson Rule”—add practical clarity for law-enforcement officers, defence counsel, and trial courts within the Sixth Circuit when assessing probable-cause determinations at roadside encounters that evolve into full custodial arrests and vehicle searches.

Summary of the Judgment

Judge Julia Smith Gibbons, writing for a unanimous panel (Cole, Gibbons & Bush, JJ.), held:

• Traffic stop: Officer Wisecup had probable cause to stop Watson for crossing the stop bar at a red light, an explicit violation of Ohio Rev. Code § 4511.13.
• Arrest: Probable cause existed for at least three separate offences—(a) the stop-bar violation, (b) driving under suspension (§ 4510.111), and (c) failure to display a licence upon lawful demand (§ 4507.35). The court rejected Watson’s claim that state classification of the suspension offence as a non-jailable misdemeanor precluded arrest, relying on Virginia v. Moore, 553 U.S. 164 (2008).
• Search: Observation of loose marijuana—unpackaged as required for state-law compliant medical marijuana—supplied probable cause to search the whole vehicle under the automobile exception, rendering the firearm’s discovery lawful.
• Sufficiency of the Evidence: Watson’s written stipulation to each element of § 922(g)(1) constituted a knowing waiver; therefore, no evidentiary deficiency existed.
• Disposition: Judgment of conviction and denial of suppression AFFIRMED.

Analysis

Precedents Cited and Their Influence

• Whren v. United States, 517 U.S. 806 (1996) – Established that any traffic violation observed by an officer provides objective justification for a stop. Whren framed the Sixth Circuit’s application of probable cause to the stop-bar infraction.
• Beck v. Ohio, 379 U.S. 89 (1964) – Provided the classic definition of probable cause, quoted to buttress the stop and arrest analysis.
• Virginia v. Moore, 553 U.S. 164 (2008) – Squarely rejected the argument that state-law limits on arrest authority alter the Fourth Amendment analysis. Watson relied heavily on Moore to dismiss the ‘non-jailable offense’ contention.
• California v. Acevedo, 500 U.S. 565 (1991) & United States v. Ross, 456 U.S. 798 (1982) – Provided doctrinal support that probable cause to believe a vehicle contains contraband authorises a search of all containers within.
• District of Columbia v. Wesby, 583 U.S. 48 (2018) – Reinforced the “substantial probability” standard for probable cause.
• Witherspoon v. United States, 633 F.2d 1247 (6th Cir. 1980) – Cited regarding the effect of a stipulation on Rule 11 procedures and sufficiency challenges.

Legal Reasoning

1. Stop Bar Violation as Probable Cause
   • The officer personally observed Watson’s vehicle positioned beyond the thick white “stop bar.”
   • Ohio Rev. Code § 4511.13 mandates stopping before the line—no subjective intent required.
   • Under Whren, even a de minimis traffic violation justifies a stop.
2. Layered Probable Cause for Arrest
   a. Traffic Infraction – The stop-bar breach alone sufficed.
   b. Suspended License – Dispatch confirmation plus prior encounter information added independent support.
   c. Refusal to Produce ID – Violation of § 4507.35 became the court’s linchpin for articulating a stand-alone ground; this element forms part of the “Watson Rule.”
   • Even if Ohio law treats driving under suspension as fine-only, Moore precludes state severity from undermining Fourth-Amendment reasonableness.
3. Automobile Exception Triggered by Visible Contraband
   • Officers saw a clear bag of loose marijuana not bearing dispensary labelling.
   • Ohio medical-marijuana regulations require original, sealed packaging. The mismatch created “substantial probability” of illegality.
   • Probable cause to believe the vehicle contained contraband validated a full-scale search, including the metal lockbox that yielded the firearm.
4. Stipulation & Sufficiency
   • Watson signed a written stipulation admitting (i) prior felony, (ii) knowledge of that status, (iii) knowing possession of the firearm, and (iv) interstate nexus.
   • Sixth Circuit precedent (Witherspoon) views such stipulations as waivers of government proof; Rule 11 procedures are encouraged but not mandatory absent a guilty plea.
   • The district court nonetheless conducted an extensive colloquy, preserving record integrity.

Impact of the Decision

The Watson opinion, though fact-specific, forges practical guidance in three sub-areas of Fourth-Amendment practice:

1. Refusal-to-Identify Arrests – Officers in Ohio and similarly-worded jurisdictions may rely on § 4507.35 (or its analogues) once foundation facts indicate unlawful operation. Defence counsel must now anticipate that identity refusal can become a distinct arrestable event.
2. Marijuana Visibility & Probable Cause – Post-legalisation patchworks often muddy probable-cause calculations. Watson clarifies that absence of medical-compliance packaging revives probable cause, endorsing an officer’s training and experiential inference.
3. Stipulated Bench Trials – The panel endorses district-court cautionary colloquies but confirms that a defendant can strategically concede every element yet still plead “not guilty” to streamline appellate review of suppression issues.

Complex Concepts Simplified

• Probable Cause – A “fair probability” standard; less than 51 % proof, but more than a hunch. It asks, “Would a reasonable officer believe a crime likely occurred?”
• Automobile Exception – Because vehicles are mobile and heavily regulated, officers may search them without a warrant if they have probable cause that evidence or contraband is inside.
• Stop Bar – The thick white line at intersections. Crossing it while stopping at a red light is a traffic violation under Ohio law.
• Stipulation of Facts – A formal agreement between parties that certain facts are true, eliminating the need for evidence or testimony on those points.
• Rule 11 Colloquy – A judge’s on-the-record conversation with a defendant to ensure a guilty plea is knowing and voluntary. While mandatory for pleas, it is discretionary (but advisable) for all-element stipulations in a bench trial.

Conclusion

United States v. Watson refines Fourth Amendment boundaries in two concrete ways. First, it confirms that a motorist’s refusal to produce a licence, coupled with objective indications of suspension, independently justifies arrest. Second, it holds that observable marijuana inconsistent with legal medical use supplies probable cause to search an entire vehicle, containers included, without a warrant.

For practitioners, the case underscores the potency of even minor traffic infractions and on-scene observations in escalating police encounters to lawful arrests and vehicle searches. For defendants contemplating stipulated bench trials, Watson illustrates both the efficiency and the irrevocable waiver such stipulations entail. Finally, for the Sixth Circuit, the decision harmonises modern marijuana realties with classical Fourth Amendment doctrine—laying down the “Watson Rule” that will likely steer lower courts when visible but non-compliant cannabis meets the open road.