“Cash-For-Flight” Stops: When a Threatened Administrative Seizure Is a Terry Detention, Not an Arrest

Introduction

United States v. Tra’ven Boyer-Letlow, No. 24-3670 (6th Cir. July 29, 2025) addresses the legal thresholds that apply when law-enforcement officers at an airport threaten to seize a traveller’s large amount of cash unless the traveller accompanies them for additional questioning. The case arose from an encounter at Cleveland Hopkins International Airport between Detective Ryan Gibbons (working with Homeland Security Investigations) and two passengers—Tra’ven Boyer-Letlow (appellant) and Dilhan Brown—who were preparing to board a flight to Los Angeles.

Key issues before the Sixth Circuit were:

Whether the encounter escalated into an unlawful arrest (or, alternatively, an unlawful investigative detention) under the Fourth Amendment.
Whether Miranda warnings were required before the subsequent interrogation.
Whether the cash, cell-phones, and the fruits of a later home search should have been suppressed as tainted evidence.

The Sixth Circuit affirmed the district court’s denial of Boyer-Letlow’s motion to suppress, holding that: (1) a threatened administrative seizure of cash transformed the conversation into a seizure (a Terry stop) but not an arrest; (2) Detective Gibbons had reasonable, articulable suspicion to support that temporary detention; and (3) because the defendant was not “in custody” for Miranda purposes, his un-Mirandized statements were admissible.

Summary of the Judgment

After observing tell-tale indicators of bulk-currency smuggling—multiple cell phones, hidden cash bulges, travelling companions disavowing each other—Detective Gibbons confronted the men in the jet-bridge. When each admitted carrying roughly $6,000, Gibbons stated he would seize the money unless they accompanied him to the Homeland Security office to “legitimize” the funds. They agreed to go. At the office, Boyer-Letlow consented to searches of his bag, his phones, and ultimately his home. A later search uncovered fentanyl, leading to federal drug charges.

The district court ruled that the interaction was consensual until the threat to seize cash was made; that, at most, the encounter became an investigative detention; and that reasonable suspicion justified the detention. On appeal, the Sixth Circuit (Judge Siler writing, joined by Judges Kethledge and Bush) agreed and affirmed.

Analysis

Precedents Cited and Their Influence

United States v. Drayton, 536 U.S. 194 (2002) – Established that police approach and questioning of bus passengers does not automatically amount to a seizure. The panel relied on Drayton to describe when a consensual encounter begins.
United States v. Place, 462 U.S. 696 (1983) – Clarified permissible scope of brief airport stops involving luggage. The Boyer-Letlow panel invoked Place for two propositions: (1) retaining a traveller’s property can effectively restrain freedom of movement, rendering the encounter a seizure; and (2) only reasonable suspicion—not probable cause—is required for a temporary detention.
United States v. Baro, 15 F.3d 563 (6th Cir. 1994) – Noted traveller’s “Hobson’s choice” when faced with surrendering cash or missing a flight. The court echoed Baro to show why a reasonable person in Boyer-Letlow’s position would not have felt free to leave.
United States v. Knox, 839 F.2d 285 (6th Cir. 1988) – Differentiated seizures from arrests in public-transportation settings. Knox helped the panel conclude that Gibbons’s conduct reflected an investigative detention, not an arrest.
Lawson v. Creely, 137 F.4th 404 (6th Cir. 2025) – Recent circuit authority defining the “free-to-leave” test. The opinion quoted Lawson for its articulation of when a seizure occurs.
Miranda v. Arizona, 384 U.S. 436 (1966) – Governing precedent for custodial interrogation. The court analyzed Miranda’s applicability but found the encounter non-custodial.
Other supporting precedents: McCallister (2022) on officer training and experience; Smith (2010) and Winfrey (1990) on evasive answers contributing to reasonable suspicion; Zabel (2022), Cantie (2021), and Dunn (2023) on Miranda “custody” in the context of investigative stops.

The Court’s Legal Reasoning

Identifying the Seizure. The conversation was consensual until Detective Gibbons threatened to administratively seize the cash. At that moment, under Place, a reasonable person would believe they must choose between surrendering property or delaying travel, effectively restraining movement—thus constituting a Fourth Amendment seizure.
Seizure vs. Arrest. Although seized, Boyer-Letlow was not under arrest because: (a) Gibbons did not physically restrain him; (b) Gibbons explicitly said he was “not under arrest”; (c) the detention was brief and investigative; and (d) his boarding pass and backpack were not confiscated. Applying Knox and Baro, the court deemed it an investigatory detention requiring only reasonable suspicion.
Reasonable Suspicion Analysis. The court aggregated multiple factors: multiple cell phones, cash split between pockets and bag (possible structuring to avoid $10,000 reporting threshold), destination city known for narcotics sourcing, bulging pockets, coordinated yet disavowed travel, and evasive answers. Under Winfrey’s totality-of-the-circumstances approach, these factors, viewed through Gibbons’s training in bulk-currency interdiction, amounted to reasonable suspicion.
Miranda Question. Because the stop was a Terry detention—not a formal arrest nor its functional equivalent—the suspect was not “in custody” for Miranda purposes. Hence, no warnings were required before questioning at the jet-bridge or in the HSI office.
Scope of Appellate Review. The panel restated Sixth Circuit standards: factual findings reviewed for clear error, legal questions de novo, and the judgment may be affirmed on any ground supported by the record (Taylor, Hill, Gill).

Impact on Future Cases and the Relevant Area of Law

Clarifies “Airport Cash Seizure” Protocols. Officers may threaten administrative forfeiture of suspicious cash, thereby initiating a Terry stop, without crossing the line into an arrest—so long as the restraints remain minimal and temporary.
Strengthens Investigative Tools for Bulk-Currency Smuggling. The decision legitimizes a common interdiction tactic: offering travellers a choice between explaining large sums of money or facing seizure, while preserving the stop’s investigatory nature.
Refines Miranda-Custody Analysis. Future defendants can expect that non-handcuffed, brief detentions—even in enclosed spaces like an HSI office—may still be deemed non-custodial.
Practical Guidance to Law-Enforcement. To stay within constitutional bounds, officers should: (a) refrain from confiscating tickets or identification, (b) overtly advise that the person is not under arrest, (c) keep the detention brief, (d) rely on articulable factors tied to their specialized training.
Litigation Strategy. Defense counsel challenging airport interdictions must focus on custody transformation (e.g., prolonged detention, transport to remote offices, or use of handcuffs) and insufficient individualized suspicion, rather than the mere threat of cash seizure.

Complex Concepts Simplified

Terry Stop / Investigatory Detention. A brief, on-the-spot detention based on “reasonable suspicion” (less than probable cause) that criminal activity is afoot. Named after Terry v. Ohio (1968).
Administrative Seizure / Forfeiture. A civil-law device allowing agencies (e.g., Homeland Security) to seize property suspected of being tied to crime, sometimes without a warrant, subject to later administrative or judicial review.
Reasonable Suspicion vs. Probable Cause. Reasonable suspicion = specific, articulable facts suggesting criminal conduct (≈30–40 % certainty). Probable cause = a fair probability that evidence of a crime will be found (≈50 %+ certainty). The former justifies brief detention; the latter is needed for arrest or search warrants.
Miranda “Custody”. A person is “in custody” when a reasonable person would feel they are under formal arrest or the functional equivalent. Not every detention equals custody.
Bulk-Currency Smuggling Threshold. Federal regulations require reporting of $10,000 or more in currency when transported internationally; smugglers will often divide cash into sub-$10,000 bundles and use multiple carriers to avoid detection.

Conclusion

United States v. Boyer-Letlow crystallizes a nuanced but critical distinction in Fourth-Amendment jurisprudence: an officer’s threat to seize cash at an airport cabin door converts a consensual encounter into a seizure but not necessarily an arrest. By emphasizing totality-of-the- circumstances, specialized officer training, and minimal restraints, the Sixth Circuit supplies a road-map for both law-enforcement and defense practitioners navigating airport interdictions involving large sums of cash. Equally important, the opinion underscores that Miranda rights do not automatically attach during such Terry detentions. As airports remain fertile grounds for drug- and cash-smuggling interdiction, this precedent will likely be cited frequently in future motions to suppress within the Sixth Circuit and beyond.