Securing the Scene: United States v. Claude Coleman and the Sixth Circuit’s Dual Clarifications on Officer-Safety Detentions and Career-Offender Predicates

Introduction

United States v. Claude Coleman, No. 23-3924 (6th Cir. Aug. 18, 2025), though designated “Not Recommended for Publication,” furnishes two noteworthy doctrinal refinements:

Officer-Safety Detention Rule. The panel extends the Maryland v. Wilson passenger-exit doctrine by approving a brief investigative detention of a vehicle’s driver who is adjacent to — but not initially implicated in — the officers’ investigation of an open-container violation committed by a sidewalk bystander.
Career-Offender Predicate Clarification. It holds that Ohio “aggravated robbery with a deadly weapon” (Ohio Rev. Code §§ 2911.01(A)(1), 2913.02) qualifies categorically as the enumerated Guideline offense of “extortion” when the charging documents specify theft under § 2913.02, distinguishing the more ambiguous record confronted in United States v. Ivy.

These twin holdings affect both Fourth Amendment street encounters and federal sentencing practice within the Sixth Circuit.

Summary of the Judgment

The court, per Chief Judge Sutton, affirmed the district court’s (N.D. Ohio) denial of Claude Coleman’s motion to suppress evidence and upheld his convictions and 360-month sentence. Key rulings include:

Search & Seizure. Coleman’s temporary detention was lawful under the officer-safety doctrine; once marijuana was spotted in plain view, officers possessed probable cause for arrest and vehicle search.
Evidentiary Issues. Cross-examination scope, admission of prior convictions, and expert opinion testimony were all within the trial court’s discretion; any lapses were harmless or unpreserved.
Sentencing. Coleman’s prior Ohio aggravated-robbery and drug-trafficking convictions rendered him a career offender under U.S.S.G. § 4B1.1.

Analysis

1. Precedents Cited and Their Influence

Terry v. Ohio, 392 U.S. 1 (1968) – baseline for reasonable-suspicion stops.
Michigan v. Summers, 452 U.S. 692 (1981) & Maryland v. Wilson, 519 U.S. 408 (1997) – authority to detain occupants during searches or traffic stops; court analogizes these to Coleman’s situation.
Bletz v. Gribble, 641 F.3d 743 (6th Cir. 2011) – outlines limits on bystander detentions; panel distinguishes it on brevity and danger.
United States v. Ivy, 93 F.4th 937 (6th Cir. 2024) – prior holding that Ohio aggravated-robbery indictment lacking § 2913.02 reference fails categorical match; Coleman’s case supplies the missing element.
Recent Sixth Circuit unpublished orders (Johnson 2024; Smith 2025) – reinforce reliance on high-crime-area plus observed violation.

2. Legal Reasoning

a. Fourth Amendment / Officer-Safety Detention

Observation of an Open-Container Violation. Probable cause existed to seize the bystander; that seizure permitted officers to “secure the scene.”
Extension to Adjacent Vehicle Occupants. Drawing on Wilson, the panel reasons that unknown risks posed by nearby, partially obscured occupants justify a brief and “limited” detention even when those occupants are not suspected of the initial infraction.
Duration and Scope. Twenty-second pause before contraband discovery is “minimal” and therefore reasonable.
Probable Cause Arises. Marijuana in plain view supplied independent grounds to arrest Coleman and search the vehicle (Arizona v. Gant).

b. Evidentiary Rulings

The appellate court applied abuse-of-discretion review and Rule-611(b) limits, finding:

Cross-examination regarding body-cam footage was tethered to Coleman’s direct testimony.
Prior convictions were introduced by the defendant, foreclosing appellate complaint (Ohler v. United States).
Opinion testimony by officers on drug quantity fell within Rule 702, and any Rule 16 notice lapse was harmless.

c. Career-Offender Analysis

Divisibility. Ohio aggravated-robbery statute is divisible; the indictment’s inclusion of §§ 2913.01 & 2913.02 identifies “theft” as the predicate element.
Categorical Match. Theft by use/brandishing of a deadly weapon necessarily involves obtaining something of value through force or fear—mirroring Guideline “extortion.”
Distinction from Ivy. In Ivy, the indictment lacked the § 2913.02 specification, forcing the court to assume the least culpable conduct; Coleman’s clarified indictment bridges that gap.
Rejection of “Deception” Hypotheticals. The panel invokes Gonzales v. Duenas-Alvarez to dismiss speculative, non-force scenarios.

3. Potential Impact

Street-Level Police Work. Officers in the Sixth Circuit now have explicit appellate support to momentarily detain vehicle occupants who are adjacent to — rather than actively participating in — the suspected offense, so long as officer-safety concerns and brevity are demonstrable.
Suppression Litigation. Defendants arguing unlawful detention will need to address the Coleman framework: (i) on-scene safety facts; (ii) brevity; and (iii) rapid emergence of independent probable cause.
Sentencing Consistency. Probation officers and district judges gain clearer guidance for classifying Ohio aggravated-robbery convictions. Where indictments reference § 2913.02 theft, those convictions count as crimes of violence via the “extortion” enumerated offense, potentially increasing Guidelines ranges.
Charging Practices. Ohio prosecutors may standardize inclusion of § 2913.02 in aggravated-robbery indictments to preserve federal sentence enhancements, while defense counsel may scrutinize indictments for such specificity.

Complex Concepts Simplified

Plain-View Doctrine: If illegal items are visible to officers who are lawfully present, no warrant is needed to seize them.
Officer-Safety Detention: Even innocent bystanders can be held briefly if necessary to protect officers during a dangerous investigation.
Categorical vs. Divisible Statutes: When evaluating prior convictions, courts compare statute elements to the federal definition. If the state statute lists multiple ways to commit the crime (i.e., is “divisible”), courts may look at charging documents to determine which version the defendant actually committed.
Career-Offender Guideline: Under U.S.S.G. § 4B1.1, defendants with two prior “crimes of violence” or “controlled-substance offenses” face higher offense levels and criminal-history categories.

Conclusion

Although unpublished, United States v. Coleman meaningfully sharpens two legal areas. First, it underscores the Sixth Circuit’s willingness to sanction short, safety-motivated detentions of peripheral individuals during minor offense investigations — an extension likely to surface in future suppression motions. Second, it clarifies that Ohio aggravated-robbery convictions do qualify as crimes of violence when the indictment specifies theft under § 2913.02, offering concrete guidance to sentencing courts and counsel. Practitioners should adjust investigative tactics, suppression strategies, and indictment reviews accordingly.