203635P.pdf   07/13/2022  United States  v.  Eric Williams
   U.S. Court of Appeals Case No:  20-3635
                          and No:  21-1069
   U.S. District Court for the Eastern District of Arkansas - Central   
   [PUBLISHED] [Shepherd, Author, with Loken and Stras, Circuit Judges] 
   Criminal case - Criminal law and sentencing. Traffic stops were supported 
   by reasonable suspicion to believe defendant's vehicles had committed 
   traffic offenses; in the first stop, the police had a reasonable suspicion 
   to believe defendant might be armed; a pat-down search was permissible, 
   and the officer did not exceed the allowable scope of the pat-down when he 
   reached inside the pocket of defendant's hoodie; inventory search of 
   defendant's vehicle was valid as the police department had an inventory 
   search policy, and the search complied with the policy; the evidence was 
   sufficient to support defendant's convictions for possession of meth and 
   cocaine with intent to distribute; the district court did not err in 
   rejecting defendant's proposed instruction that a heightened showing is 
   required in constructive possession cases when the contraband is found in 
   the home of a third party; government's cross-appeal challenging the 
   extent of the downward variance in the case rejected, as any error in the 
   district court's analysis did not affect the government's substantial 
   rights as there was no reasonable probability that, but for the error, the 
   court would have imposed a higher sentence.