United States of America v. Ronnard Williams

United States Court of Appeals
FOR THE DISTRICT OF COLUMBIA CIRCUIT
Argued December 13, 2024 Decided August 26, 2025
No. 23-3044
UNITED STATES OF AMERICA,
APPELLEE
v.
RONNARD WILLIAMS,
APPELLANT
Appeal from the United States District Court
for the District of Columbia
(No. 1:20-cr-00088-2)
Mary H. Schnoor argued the cause for appellant. With
her on the briefs were A.J. Kramer, Federal Public Defender,
and Rosanna Taormina, Assistant Federal Public Defender.
Tony Axam Jr., Assistant Federal Public Defender, entered an
appearance.
Peter F. Andrews, Assistant U.S. Attorney, argued the
cause for appellee. With him on the brief were Matthew M.
Graves, U.S. Attorney, and Chrisellen R. Kolb and Nicholas P.
Coleman, Assistant U.S. Attorneys.
Before: WALKER, CHILDS and PAN, Circuit Judges.

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Opinion for the Court filed by Circuit Judge WALKER.
Opinion concurring in the judgment filed by Circuit Judge
CHILDS.
WALKER, Circuit Judge: Police officers approached an
illegally parked car with illegally tinted windows. After the
driver partially lowered his window to speak with them, the
police ordered him to lower the windows more. Because he
complied, the police were able to see a gun, which led to his
arrest, prosecution, and conviction.
Appealing his conviction, the driver says that the order to
lower his windows violated the Fourth Amendment. But
Pennsylvania v. Mimms held that “once a motor vehicle has
been lawfully detained for a traffic violation, the police officers
may order the driver to get out of the vehicle without violating
the Fourth Amendment’s proscription of unreasonable
searches and seizures.” 434 U.S. 106, 111 n.6 (1977). That’s
because the “mere inconvenience” of exiting a car “cannot
prevail when balanced against legitimate concerns for the
officer’s safety.” Id. at 111.
For the same reason, at a lawful traffic stop, the police may
order a driver to lower his windows when something like the
window’s tint makes it hard to see inside the car. The
government’s “legitimate concerns for the officer’s safety”
outweigh the “mere inconvenience” to the driver of lowering
his windows. Id.
I. Background
Around 11:00 p.m., Metropolitan Police Department
officers approached a car that was illegally parked, with
illegally tinted windows. After an officer tapped on his

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window, the driver, Ronnard Williams, lowered his
window — but only slightly. As the bodycam footage shows,
the window tint made it hard for the police to see inside the car:
After some discussion with Williams, the police ordered
him to roll his windows lower. Williams complied. That
allowed the police to see a gun at the foot of a passenger in the
backseat.
An officer opened the door and grabbed the gun. The
police ordered Williams and the passenger out of the car and
placed them under arrest. A search of the car revealed another
gun, marijuana, and $2,000 in cash.
A federal grand jury indicted Williams for violating a
federal statute that prohibits felons from possessing a firearm.
See 18 U.S.C. § 922(g)(1). Williams then moved to suppress
the evidence found in his car. He argued that the order to
lower his windows was an unreasonable search in violation of
the Fourth Amendment.
The district court denied the motion. A jury convicted
Williams of unlawful possession of a firearm by a felon. The

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court sentenced him to three years and five months in prison,
with credit for time served.
Williams appealed, and we affirm.
II. Analysis
Before us, Williams does not argue that the police lacked
probable cause for a lawful traffic stop.1 Nor does he dispute
that the police could grab the gun in plain view after he obeyed
their order to lower his tinted windows.2 Rather, Williams
says that their order, which put the gun in plain view, violated
the Fourth Amendment.3
A. The Fourth Amendment and Mimms
The Fourth Amendment guarantees the “right of the
people to be secure in their persons, houses, papers, and effects,
against unreasonable searches and seizures.” U.S. Const.
amend. IV. Whether a search is lawful under the Fourth
Amendment depends on “the reasonableness in all the
circumstances of the particular governmental invasion of a
citizen’s personal security.” Terry v. Ohio, 392 U.S. 1, 19
(1968). In determining reasonableness, we “balance . . . the
1 See Arizona v. Johnson, 555 U.S. 323, 327 (2009) (a traffic stop is
lawful when it is legally permissible “for police to detain an
automobile and its occupants pending inquiry into a vehicular
violation”).
2 See Kentucky v. King, 563 U.S. 452, 463 (2011) (under certain
circumstances the police “may seize evidence in plain view” without
a warrant).
3 We review questions of law de novo and factual findings for clear
error. United States v. Hutchings, 99 F.4th 604, 607 (D.C. Cir.
2024).

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public interest and the individual’s right to personal security
free from arbitrary interference by law officers.” United
States v. Brignoni-Ponce, 422 U.S. 873, 878 (1975).4
Applying that standard, the Supreme Court held in
Pennsylvania v. Mimms that “once a motor vehicle has been
lawfully detained for a traffic violation, the police officers may
order the driver to get out of the vehicle without violating the
Fourth Amendment’s proscription of unreasonable searches
and seizures.” 434 U.S. 106, 111 n.6 (1977). There, the
government interest in officer safety was “both legitimate and
weighty” because of “the inordinate risk confronting an officer
as he approaches a person seated in an automobile.” Id. at
110.5 By contrast, “the order to get out of the car” was a “de
minimis” intrusion into the driver’s privacy. Id. at 111. Since
Mimms, the Court has repeatedly reaffirmed its “bright-line
rule” that “a police officer may as a matter of course order the
driver of a lawfully stopped car to exit his vehicle.” United
States v. Bullock, 510 F.3d 342, 345 (D.C. Cir. 2007) (cleaned
up).6
4 Cf. Luke M. Milligan, The Forgotten Right to Be Secure, 65
HASTINGS L.J. 713, 717 (2014) (the Fourth Amendment protects “the
right of the people to be secure,” not just the “right to be ‘spared’ an
unreasonable search or seizure” (cleaned up)).
5 Cf. Terry, 392 U.S. at 23 (“Certainly it would be unreasonable to
require that police officers take unnecessary risks in the performance
of their duties.”).
6 See, e.g., Maryland v. Wilson, 519 U.S. 408, 415 (1997) (“an
officer making a traffic stop may order passengers to get out of the
car pending completion of the stop”); Michigan v. Long, 463 U.S.
1032, 1047-48 (1983) (same); Rakas v. Illinois, 439 U.S. 128, 155
n.4 (1978) (Powell, J., concurring) (similar).

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B. Applying Mimms
This case is like Mimms. The Government’s “legitimate
and weighty” interest in officer safety easily outweighs the
“mere inconvenience” of rolling down tinted windows.
Mimms, 434 U.S. at 110-11.
Consider first the interest in officer safety. “Approaching
a stopped car . . . is one of the more perilous duties imposed on
law enforcement officers.” United States v. Holmes, 385 F.3d
786, 791 (D.C. Cir. 2004) (Roberts, J.). Is the driver drunk?
High? Armed? Are there any passengers? Has anyone in
the car committed a violent crime? Do they intend to? What,
if anything, are they hiding? And what will they do to keep it
hidden? See Barnes v. Felix, 145 S. Ct. 1353, 1361 (2025)
(Kavanaugh, J., concurring).
Because of these known unknowns — plus the unknown
unknowns — traffic stops are “inherently risky for police
officers.” Id.; cf. DONALD RUMSFELD, KNOWN AND
UNKNOWN: A MEMOIR xiii (2011). “People detained for
minor offenses such as ordinary traffic violations can turn out
to be the most devious and dangerous criminals.” Barnes, 145
S. Ct. at 1361 (Kavanaugh, J., concurring) (cleaned up).
That’s one reason “that a significant percentage of murders of
police officers occurs when the officers are making traffic
stops.” Mimms, 434 U.S. at 110 (cleaned up); see also Long,
463 U.S. at 1049 (“roadside encounters between police and
suspects are especially hazardous”); Statistics on Law
Enforcement Officer Deaths in the Line of Duty from January
through August 2024, FBI, https://perma.cc/XS86-6DH2.
“When, during already dangerous traffic stops, officers
must approach vehicles whose occupants and interiors are
blocked from view by tinted windows, the potential harm to

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which the officers are exposed increases exponentially, to the
point, we believe, of unconscionability. Indeed, we can
conceive of almost nothing more dangerous to a law
enforcement officer in the context of a traffic stop than
approaching an automobile whose passenger compartment is
entirely hidden from the officer’s view by darkly tinted
windows.” United States v. Stanfield, 109 F.3d 976, 981 (4th
Cir. 1997) (emphasis omitted).
Consider next the driver’s minimal interest in not lowering
his window. If an order to exit the vehicle is a “de minimis”
intrusion and “at most a mere inconvenience,” then so too is an
order to lower the windows. Mimms, 434 U.S. at 111. If
anything, the intrusion here is even smaller. The driver
exposes less by opening a window than by opening a door.7
And the driver is inconvenienced less than by exiting the
car — for the same reason it’s easier for drive-thru workers to
hand fast food through open windows rather than open doors.
Because a “mere inconvenience cannot prevail when
balanced against legitimate concerns for the officer’s safety,”
we hold that the police did not violate the Fourth Amendment
when they ordered Williams to lower his windows. Id.8
7 Though not necessary for our analysis, we note that opening a car
door will often turn on the car’s interior lights.
8 Cf. Stanfield, 109 F.3d at 981 (during a lawful traffic stop, an
officer may lawfully open a car door to view the interior when the
windows are heavily tinted and may conceal threats); United States
v. Brown, 334 F.3d 1161, 1168-69 (D.C. Cir. 2003) (similar, citing
Stanfield approvingly); United States v. Matthews, 422 F. Supp. 3d
1235, 1251 (W.D. Ky. 2019) (an officer’s “quick decision to open
the car door” when “he could not see inside the vehicle because of
the tint on the windows” was “prudent” and constitutional).

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III. Conclusion
When something like the tint of a car’s windows makes it
hard to see inside, the police can order the driver to lower the
windows during a lawful traffic stop — including a stop
justified by suspicion of the windows’ illegal tint.9
We therefore affirm.
So ordered.
9 To the extent other courts in similar situations have applied a
standard more demanding or fact-specific than this bright-line rule,
we disagree with them for the reasons already explained. See, e.g.,
United States v. Holley, 709 F. App’x 602, 605 (11th Cir. 2017) (“the
search stemmed from some probable cause focusing suspicion on the
individual affected by the search”); United States v. Jones, No. 1:19-
cr-20693, 2021 WL 2156195, *3-4 (E.D. Mich. May 27, 2021)
(“unconstitutional search” where the officer opened the door of a car
with tinted windows after the driver “had his windows rolled down”
because there was “no reason to believe that opening the driver-side
door was necessary for officer safety”); United States v. Green, 437
F. Supp. 2d 38, 41-42 (D.D.C. 2006) (“a tinted window violation . . .
does not justify the search of a person or his or her vehicle without
more”); Jackson v. United States, 56 A.3d 1206, 1213 (D.C. 2012)
(“the facts of this case do not establish that the tinting was a
meaningful factor justifying [the officer’s] decision not only to open
the door, but to cross the plane of the van and conduct a Terry search
of the vehicle’s interior” (cleaned up)).

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CHILDS , Circuit Judge, concurring in the judgment: I
concur insofar as the majority affirms the district court’s denial
of Ronnard Williams’ motion to suppress. The record
establishes specific, articulable facts showing that the traffic
stop was lawful, that it was difficult for the officers to see inside
Williams’ vehicle, and that instructing him to roll down his
windows to unblock their view was a minimal intrusion under
the balancing test in Pennsylvania v. Mimms, 434 U.S. 106
(1977). Williams’ unlawful window tint, combined with
additional officer safety concerns, diminished his privacy
interest and heightened officer safety interests.
I do not, however, agree with the majority’s reasoning or
its adoption of a categorical rule. The majority holds that
whenever “something like the tint of a car’s windows makes it
hard to see inside, the police can order the driver to lower the
windows during a lawful traffic stop — including a stop
justified by suspicion of the windows’ illegal tint.” Majority
Op. at 8. This broad rule is inconsistent with Mimms and its
progeny, invites unnecessary intrusions, and is unmoored from
the fact-specific balancing the Fourth Amendment requires. It
may fit the facts of this case, but it offers no limiting principle
and risks misuse in circumstances that do not justify the
intrusion.
Under the majority’s approach, even tint that proves lawful
yet still obstructs visibility could justify a full, compelled
exposure of the interior. If legally obstructed visibility alone
sufficed, then any officer could transform a stop for a minor
parking or traffic infraction into a warrantless inspection of a
vehicle’s interior, authorizing full exposure of deliberately
concealed areas without an articulable safety threat. That
reading collapses the line between precaution and pretext and
erodes the very privacy interests the Fourth Amendment
protects. Because I cannot endorse an approach that risks the
quiet, gradual erosion of personal liberty under the banner of
bright-line clarity, I concur in the judgment.

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I.
A.
One late night, four officers from the District’s
Metropolitan Police Department’s (MPD) specialized Gun
Recovery Unit (GRU) were on duty in two unmarked cars.
GRU officers are authorized to make “proactive” patrol stops,
which are searches of persons and vehicles for firearms.1
While the GRU’s objective is to conduct firearm interdiction,
there is an expectation that they address and enforce the rules
and regulations of the District.
While patrolling, the GRU officers observed Williams’
vehicle parked within five feet of a parking lot entrance, idling
with its headlights on, and displaying what appeared to be
illegally tinted windows. Two officers approached on foot
from opposite sides. One initiated the stop, during which
Williams partially lowered his driver’s-side window to speak
with the officer, who cited him for a tint violation. The second
supervising officer walked from the driver’s-side window
around the rear of the car toward the front, where he observed
a second passenger in the backseat through the windshield.
After a second patrol car arrived, the officers ordered
Williams to roll all windows “all the way down.” When
Williams partially lowered them, the officers shined flashlights
into the interior cabin without breaking the window plane. The
supervising officer at the rear passenger side window observed
1 D.C. Council Police Reform Comm’n, Decentering Police to
Improve Public Safety: A Report of the D.C. Police Reform
Commission 21 (Apr. 1, 2021), [https://perma.cc/M56W-TULG].
GRU practices have been criticized for “aggressive stop, pursuit, and
search tactics that bump up against—and sometimes cross—
constitutional boundaries.” Id. at 94.

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a male, awkwardly positioned and reclined in his seat. The
officer at the driver’s-side window gestured by snapping her
fingers to the supervising officer, prompting him to direct his
flashlight toward the rear passenger side floorboard, where he
saw a firearm in plain view. Both occupants were arrested, and
a subsequent search of the trunk yielded a second firearm.
B.
After evidentiary hearings in February, April, and May
2022, the district court denied Williams’ motion to suppress. It
credited the supervising officer’s testimony as corroborated by
body-worn camera footage. The court rejected Williams’
reliance on MPD internal-affairs findings—resulting in the
officer’s suspension and administrative reprimand for
unrelated Fourth Amendment violations during GRU patrols—
as grounds to discount his credibility. The court found that
officers reasonably determined Williams’ car was parked
within five feet of a parking lot entrance and that its window
tint appeared illegal, later testing at 9% light transmittance—
below the legal limit. It also credited the officer’s explanations
rebutting Williams’ claims that oncoming headlights prevented
him from seeing the tint, that his testimony was inconsistent
across proceedings, and that tint enforcement fell outside the
GRU’s firearm-interdiction mission.
On the law, the court held that the stop was justified by
both tint and parking violations. Ordering Williams to roll
down his windows did not violate the Fourth Amendment
under Mimms, 434 U.S. at 110, because, in the district court’s
view, the dark tint impeded visibility and officer safety is a
weighty governmental interest. The court found the privacy
intrusion to be “de minimis” and concluded that the firearm in
the backseat was lawfully seized under the plain-view doctrine.
The court further held that the officers had probable cause to

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search the trunk after recovering the firearm, given the
possibility of additional weapons or contraband, the backseat’s
access opening to the trunk area, recent reports of shootings
nearby, and the presence of two occupants.
C.
Williams was indicted under 18 U.S.C. § 922(g)(1) for
possessing a firearm. After evidentiary hearings, the district
court denied his motion to suppress. A jury convicted him in
December 2022, and he was sentenced to 41 months
imprisonment, three years of supervised release, and a $100
special assessment. Williams timely appealed.
II.
The Fourth Amendment protects against “unreasonable
searches and seizures.” U.S. Const. amend. IV. The
lawfulness of a search depends on the “reasonableness in all
the circumstances” of the intrusion. Terry v. Ohio, 392 U.S. 1,
19 (1968). To assess reasonableness, courts must “balance . . .
the public interest and the individual’s right to personal
security free from arbitrary interference by law officers.”
United States v. Brignoni-Ponce, 422 U.S. 873, 878 (1975).
My colleagues liken this case to Mimms, reasoning that
ordering a driver out of a car is akin to directing a driver to roll
down his windows, and that both are “at most a mere
inconvenience.” Majority Op. at 7. That analogy holds true in
this case, where the window tint was so dark that even artificial
light could not illuminate the driver’s immediate reach. But it
does not fit neatly when lawful tint limits visibility.
For vehicles with no window tint, lowering windows is a
minimal intrusion because it adds little to what already lies in

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plain view. Where tint is illegal, the privacy interest is
diminished, and the safety interest is substantial.2 Lawful tint,
however, presents a different case. Rolling down those
windows may expose areas deliberately and lawfully concealed
from public view. That the exercise of rolling down a window
may involve less physical effort than exiting a car does not
make the two intrusions equivalent.3 An exit order may reveal
no more of the cabin than already visible, while lowering
legally tinted windows may expose it entirely. Unlike Mimms,
where the intrusion reduced risks of concealed movement and
established face-to-face engagement, an order to roll down
lawfully tinted windows is an intrusion that shifts the officer’s
attention from the person to the cabin’s contents, revealing
more than Mimms contemplated. 434 U.S. at 110.
In my view, the mere belief that visibility may be limited
is not categorically sufficient to justify compelled cabin
exposure. Officer safety is undoubtedly weighty, Arizona v.
Johnson, 555 U.S. 323, 331–32 (2009), but Mimms should not
be expanded to deem safety concerns automatically justified in
2 A driver might claim greater privacy in areas lawfully concealed by
legal tint, but Williams’ use of illegal tint defeats that claim. “There
is no legitimate expectation of privacy shielding that portion of the
interior of an automobile which may be viewed from outside . . . by
either inquisitive passersby or diligent police officers.” Texas v.
Brown, 460 U.S. 730, 739–40 (1983) (citation omitted).
3 The majority analogizes a compelled lowering of the window to the
ease of handing fast food through a drive-thru window, reasoning
that it is less revealing than opening a door or exiting the vehicle.
Majority Op. at 7. That trivializes the Fourth Amendment and
diverts attention from the proper inquiry: whether, on the facts at
hand, the instruction was reasonable. The Constitution does not
measure the legitimacy of a search by its ease of execution.
Voluntarily opening a window to accept food at a drive-thru differs
in kind from being compelled to do so for a warrantless inspection.

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every measure that might improve visibility. The Fourth
Amendment requires that an instruction to improve safety be
reasonable under the specific circumstances, not in the abstract.
See Brignoni-Ponce, 422 U.S. at 878. Mimms permits such an
intrusion only if it is supported by facts “available to the officer
at the moment of the seizure or the search.” 434 U.S. at 112
(quoting Terry, 392 U.S. at 21–22). As framed by the majority,
the rule invites intrusion on the basis of mere hunches, enabling
even a pretextual stop dressed up as a safety concern over
window tint to force visual access to a vehicle’s interior.4 Even
if one believes, as the majority suggested at oral argument, that
“if the interest that we’re trying to promote or protect here is
officer safety, if they can’t see, they can’t see. It doesn’t matter
if this was a legal tint or illegal tint,” Oral Arg. Tr. 34, the
Constitution still demands that the intrusion be grounded in
articulable facts, not an undifferentiated assertion of safety.
Imagine a motorist driving home from work in the early
evening, windows rolled up against the cold. The vehicle’s tint
is lawful, and the driver commits no traffic violation. An
officer on routine patrol, citing “visibility concerns,” stops the
4 The Fourth Amendment’s reasonableness inquiry is objective: if the
facts justify a stop, the officer’s motive does not matter. See Whren
v. United States, 517 U.S. 806, 813–14 (1996) (“Subjective
intentions play no role in ordinary, probable-cause Fourth
Amendment analysis.”). Thus, the stop here, whether motivated by
a genuine traffic concern or a pretext, was valid. But Whren does not
authorize every further intrusion; each must be independently
justified. “A determination that reasonable suspicion exists,
however, need not rule out the possibility of innocent conduct.”
United States v. Arvizu, 534 U.S. 266, 277 (2002) (quoting Illinois v.
Wardlow, 528 U.S. 119, 125 (2000)). The majority’s approach
collapses the distinction between a valid stop and an independent
intrusion, allowing compelled exposure of a vehicle’s interior
without the individualized basis the Fourth Amendment demands.

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car and orders the driver to lower all windows. There is no
report of crime, no erratic driving, no furtive movement, and
no other sign of danger. Under the majority’s reasoning, the
mere fact that tint limits a perfect view could justify this
intrusion. That rule would allow officers to compel a vehicle’s
interior exposure without individualized suspicion, weakening
the Fourth Amendment’s protection against arbitrary
interference. The harm lies in the government compelling
access to private space without adequate justification. Rights
ought not be measured by a person’s willingness to forfeit them
in harmless encounters, but by whether the government must
meet the Constitution’s requirement for specific and articulable
grounds before it intrudes upon the individual.
Case law underscores the need for particularized facts. In
United States v. Brown, we upheld an officer’s opening of a car
door not simply because window tint obstructed the view, but
because the officers were responding to gunfire, saw a
passenger switch seats, and observed suspicious behavior near
the vehicle. 334 F.3d 1161, 1163–64 (D.C. Cir. 2003). In
United States v. Stanfield, the Fourth Circuit upheld a similar
intrusion based on multiple, specific indicators: a double-
parked car in a high-crime area, a driver speaking with a known
criminal, and heavily tinted windows. 109 F.3d 976, 978–79
(4th Cir. 1997). Neither court approved such an intrusion based
on window tint alone. Moreover, the Stanfield court made clear
that its holding addressed only traffic stops where dark tint
magnified the threat to “the point of . . . unconscionability.” Id.
at 981. The majority’s rule departs from that careful limitation,
extending authority to situations far removed from the
extraordinary facts that justified the result in Stanfield.
Here, the stop occurred late at night in a high-crime area
with recent reports of violence. The car was illegally parked,
and the tint was so dark that the driver remained obscured even

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after partially lowering the window and with artificial light
directed inside. A passenger was discovered only after a
windshield survey. Those facts, taken together, bear closer
resemblance to the elevated-risk conditions described in Brown
and Stanfield than to a routine traffic encounter.
Absent such circumstances, obstructed visibility alone
does not suffice. Many motorists lawfully use tint to preserve
privacy. They do not forfeit that interest merely by passing
through high-crime areas or by committing minor parking
violations. Even if an officer can’t see clearly into a vehicle,
the driver still has a constitutional privacy interest when the tint
is legal, because that level of concealment is authorized by
law. 5 Those circumstances may heighten an officer’s alertness,
but each alone does not transform a motorist into a threat. That
distinction matters both to avoid legitimizing suspicion by
association and to prevent intrusions on liberty without
sufficient basis. Otherwise, we risk eroding the line between
legitimate precaution and impermissible pretext, at the expense
of the privacy the Fourth Amendment was intended to protect.
III.
For the foregoing reasons, I concur in the judgment.
5 Factory-installed tint may appear opaque in bright sunlight. At
night, lawful tint can make a driver difficult to see when cabin lights
are off or street lighting is poor. Rain or condensation can further
reduce transparency, as can the angle of approach or the darker tint
permitted on rear passenger windows in many jurisdictions. None
of these conditions, alone, poses a genuine safety risk.

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