United States v. Edwards: Illinois Voluntary Manslaughter as an ACCA “Violent Felony” and the Limits of Force in Terry Stops

I. Introduction

In United States v. Jackie Edwards, Nos. 21-3114 & 21-3094 (7th Cir. Dec. 17, 2025), the Seventh Circuit resolved two important questions:

• How far officers may go—guns drawn, AR‑15 displayed, handcuffing, and physical takedown—without converting a Terry stop into a full-blown arrest under the Fourth Amendment; and
• Whether a 1982 Illinois conviction for voluntary manslaughter (the predecessor to today’s Illinois “second-degree murder”) qualifies as a “violent felony” under the Armed Career Criminal Act (“ACCA”), 18 U.S.C. § 924(e).

The court unanimously affirmed Edwards’s felon-in-possession conviction under 18 U.S.C. § 922(g)(1), rejected a host of suppression, evidentiary, and sufficiency challenges, but vacated his 60‑month sentence. It held that Illinois voluntary manslaughter is categorically a “violent felony” under ACCA’s elements clause, making Edwards an Armed Career Criminal subject to a 15‑year mandatory minimum. The case also offers a robust endorsement of officer safety measures during investigative detentions based on reasonable suspicion that the suspect is armed and dangerous.

II. Summary of the Opinion

Parties and posture. Edwards, with multiple prior felonies, was stopped by a DEA task force after a Title III wiretap investigation revealed drug dealing, robbery concerns, and his admission that his pistol was at home. Officers followed him into Chicago, observed a countersurveillance driving maneuver, initiated a stop, and recovered a handgun from his coat pocket after a brief, forceful struggle. A jury convicted him of being a felon in possession. Edwards appealed; the government cross-appealed his non-ACCA sentence.

Holdings.

• Fourth Amendment: The stop and frisk were supported by reasonable suspicion. The officers’ drawn weapons, AR‑15, physical removal from the car, handcuffing, and brief ground takedown did not convert the encounter into an arrest requiring probable cause, given the totality of circumstances and safety concerns.
• Sufficiency of the evidence: The jury’s rejection of Edwards’s “planted gun” theory was entirely rational; the evidence easily supported the verdict.
• Evidentiary rulings / Rule 33: The district judge’s management of references to the underlying wiretap drug investigation, including striking both opening statements and admitting only very limited background testimony, was well within her discretion and, if anything, favorable to the defense. No new trial was warranted.
• Sentencing / ACCA: Edwards’s 1982 Illinois conviction for voluntary manslaughter is a “violent felony” under ACCA’s elements clause. Relying on United States v. Teague, 884 F.3d 726 (7th Cir. 2018), and Illinois caselaw on transferred intent, the court held that this offense, though worded in part with “negligently or accidentally,” is fundamentally an intentional homicide offense. The sentence was vacated and the case remanded for resentencing under ACCA.

The decision thus solidifies the classification of Illinois voluntary manslaughter/second-degree murder as a qualifying ACCA predicate and clarifies that substantial, even militarized-seeming, police force can remain within Terry-stop boundaries when grounded in specific safety concerns.

III. Detailed Analysis

A. Factual and Procedural Background

DEA agents monitoring a Title III wiretap of a St. Louis heroin dealer intercepted calls linking Jackie Edwards to marijuana distribution in the Chicago area. The intercepted calls revealed:

• Edwards’s drug transactions with supplier Thayer Daineh;
• Edwards’s fear of being targeted for a robbery;
• Plans to identify and “get” the robber; and
• Edwards’s admission that his “pistol” and “everything” were at his home.

Edwards had two prior federal drug-trafficking convictions and a 1982 Illinois voluntary-manslaughter conviction. DEA and task-force officers:

• Observed Daineh visit Edwards’s home with a bag and leave with a brown bag and a white plastic bag;
• Coordinated a traffic stop on Daineh’s vehicle, seizing about $30,000 in cash; and
• Prepared a search warrant for Edwards’s home.

When Edwards left his home for Chicago, officers followed him in unmarked cars for about 26 miles. Near his laundromat at 69th & Racine, he made five consecutive right turns (“squaring the block”), a known countersurveillance maneuver, then pulled to the curb. Officers:

• Stopped behind him with emergency lights;
• Approached wearing tactical gear; one carried an AR‑15 rifle, others drew sidearms pointed down;
• Ordered Edwards to show his hands and exit; he instead leaned on the horn, reached toward the console, and tried to close the window;
• Physically pulled him out, attempted a frisk, during which he twisted (“bladed”) his right side away to conceal his coat pocket; and
• Took him to the ground, handcuffed him, and recovered a handgun from his right coat pocket.

The entire stop—from curb to gun recovery—lasted under six minutes. After losing a suppression motion and a jury trial, Edwards moved unsuccessfully for judgment of acquittal and a new trial. At sentencing, the court refused to apply ACCA based on the probation office’s view that Illinois voluntary manslaughter is not a “violent felony.” The government cross-appealed that legal conclusion.

B. Fourth Amendment: Terry, Force, and De Facto Arrest

1. Reasonable suspicion and the collective-knowledge doctrine

The court regarded Edwards’s argument that the officers lacked reasonable suspicion as “borderline frivolous.” Applying Terry v. Ohio, 392 U.S. 1 (1968), and its progeny such as United States v. Eymann, 962 F.3d 273 (7th Cir. 2020), and United States v. Reedy, 989 F.3d 548 (7th Cir. 2021), the panel emphasized:

• Reasonable suspicion requires “specific and articulable facts” and rational inferences showing that “criminal activity is afoot,” a standard “more than a hunch but less than probable cause.”
• Officers may rely on the collective-knowledge doctrine (Illinois v. Andreas, 463 U.S. 765 (1983); Eymann; United States v. Kahn, 937 F.3d 1042 (7th Cir. 2019)), aggregating information known across a coordinated investigation.

Here, collectively, officers knew that:

• Edwards was engaged in drug trafficking, as shown by intercepted, coded calls;
• He feared a robbery and wanted to “get” the would‑be robber;
• He planned to travel into Chicago and had indicated that his “pistol” was at his residence;
• He had prior serious felonies, including two federal trafficking convictions and a homicide (voluntary manslaughter) conviction;
• His supplier had just collected drug proceeds and was found with $30,000 in cash after leaving Edwards’s home; and
• He engaged in “squaring the block,” a countersurveillance maneuver, just before stopping.

Taken together, these facts easily generated reasonable suspicion that:

• Edwards was involved in ongoing drug activity, and
• He was likely armed and potentially headed into a violent confrontation.

Under Seventh Circuit precedent, the link between drug trafficking and guns is well established (United States v. Askew, 403 F.3d 496 (7th Cir. 2005); United States v. Bullock, 632 F.3d 1004 (7th Cir. 2011)), making the suspicion that he was armed eminently reasonable.

2. Use of force during an investigative stop

The more substantial issue was whether the degree of force—multiple officers, drawn firearms, an AR‑15, window strike, takedown, handcuffing—transformed this Terry stop into a de facto arrest requiring probable cause.

Drawing on Bullock, United States v. Olson, 41 F.4th 792 (7th Cir. 2022), and similar cases, the court reaffirmed several key principles:

• There is no “litmus-paper test” distinguishing a permissible investigative stop from an arrest; context and totality control.
• Because Terry stops can be dangerous, officers may draw weapons, physically restrain suspects, and even handcuff them without necessarily converting the interaction into an arrest—if those measures are reasonably related to safety and the investigation’s needs.
• The central question is whether the surrounding circumstances “would support an officer’s legitimate fear for personal safety.” (Olson).

Applying those principles, the panel found the officers’ conduct reasonable:

• They had specific information that Edwards was armed and had a history of violent and drug-related crime.
• He drove in a way suggesting he was concerned about being followed (countersurveillance).
• During the stop, he:
  • Ignored commands to show his hands and exit;
  • Reached toward the center console;
  • Leaned on the horn (escalating chaos and attracting attention);
  • Attempted to close the window as officers approached; and
  • Resisted the frisk, repeatedly turning his right side away from officers (“blading”) in an apparent attempt to conceal something.

Against this backdrop, using drawn weapons, briefly striking toward the window, pulling Edwards from the vehicle, taking him to the ground, and applying handcuffs were all seen as responsive safety measures—properly “calibrated to the escalating risk” rather than markers of an arrest. The court explicitly rejected the notion that the display of an AR‑15 or multiple sidearms is per se synonymous with arrest, focusing instead on why those measures were employed here.

3. Duration of the stop

The length of the encounter—less than six minutes from curb to gun discovery—also favored the government. Citing Reedy and Bullock, the court reiterated that:

• There is no rigid time limit on a Terry stop; reasonableness depends on the investigative tasks being pursued and officer diligence.
• Here, any modest extension of time was largely caused by Edwards’s own resistance, not officer delay or fishing expeditions.

On these facts, the stop did not morph into a de facto arrest, and the suppression motion was correctly denied.

C. Rule 29: Sufficiency of the Evidence

Edwards’s Rule 29 motion, and his appellate sufficiency arguments, rested on the theory that the officers planted the gun. The court’s response was blunt: under the highly deferential standard articulated in cases like United States v. Armbruster, 48 F.4th 527 (7th Cir. 2022), and United States v. LeBeau, 949 F.3d 334 (7th Cir. 2020), this claim was “frivolous.”

Key points:

• The jury viewed video of the encounter.
• Multiple officers gave consistent testimony about recovering the firearm directly from Edwards’s right coat pocket during an active, resistance-filled frisk.
• The defense’s “plant” theory lacked any evidentiary support beyond speculation and cross-examination rhetoric.

Given the standard—reversal only if “no rational trier of fact could have found the defendant guilty”—the panel had no difficulty affirming the denial of the Rule 29 motion.

D. Rule 33: Trial Management and Evidentiary Rulings

Edwards’s Rule 33 motion for a new trial focused on alleged judicial errors in handling:

• References to the DEA and the underlying drug/Title III investigation; and
• The striking of both parties’ opening statements.

Under United States v. Hamdan, 910 F.3d 351 (7th Cir. 2018), and United States v. Conley, 875 F.3d 391 (7th Cir. 2017), Rule 33 relief is reserved for the “most extreme cases,” and appellate review is highly deferential. The key features here:

• Pretrial ruling: The judge excluded substantive evidence about the drug/Title III investigation to avoid undue prejudice in a gun case. This strongly favored the defense.
• Opening statements:
  • The prosecutor, in describing the officers, briefly used “Drug Enforcement Administration.”
  • The defense objected; the judge initially overruled but then, the next day, instructed the government to use “federal agents” only.
  • Defense counsel’s own opening heavily emphasized the officers’ force and suggested misconduct and planting of evidence.
  • Concerned that both openings were “problematic,” the judge struck both and instructed the jury not to consider them at all—again, a symmetric remedy.
• “Opening the door” and background testimony:
  • Defense cross-examination of Officer Campbell attempted to imply that officers had no reason to suspect Edwards had a gun or to use force.
  • The prosecutor argued that this misuse of the suppression ruling created a misleading picture, warranting limited background about the investigation (including the “pistol” call).
  • The judge concluded the defense had “opened the door” to some background context but still to admit the wiretap “pistol” call itself.
  • She allowed only very narrow testimony from Agent Lech that: (1) she supervised the case, and (2) before the stop, she told the team that Edwards might have a gun.

The Seventh Circuit characterized these rulings as “noticeably protective of the defense.” The judge maintained tight control over potentially prejudicial drug evidence while permitting the jury a minimally accurate picture of why officers approached the stop as they did. There was no abuse of discretion, and certainly nothing rising to the “interest of justice” standard for a new trial.

E. Sentencing and ACCA: Illinois Voluntary Manslaughter as a “Violent Felony”

1. ACCA’s elements clause and the categorical approach

The central legal development in Edwards concerns ACCA’s treatment of Illinois voluntary manslaughter. Under ACCA, a defendant convicted of § 922(g)(1) faces a mandatory minimum 15‑year sentence if he has three qualifying prior convictions for:

• a “violent felony,” or
• a “serious drug offense.”

“Violent felony” is defined in relevant part as any crime punishable by more than one year that “has as an element the use, attempted use, or threatened use of physical force against the person of another.” 18 U.S.C. § 924(e)(2)(B)(i) — the so‑called elements clause.

Under the categorical approach required by ACCA and cases like Borden v. United States, 593 U.S. 420 (2021), the court examines the elements of the statute of conviction, not the defendant’s actual conduct, to see whether those elements necessarily involve the use of violent physical force with at least a certain mental state.

2. The Illinois statute: text and history

Edwards’s 1982 conviction was under the then-effective Illinois voluntary-manslaughter provision, Ill. Rev. Stat. ch. 38, ¶ 9‑2 (1961), which provided:

A person who kills an individual without lawful justification commits voluntary manslaughter if at the time of the killing he is acting under a sudden and intense passion resulting from serious provocation by:
(1) The individual killed, or
(2) Another whom the offender endeavors to kill, but he

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