D.C. Appeals Court Tosses Gun Conviction, Says Fleeing Cops Isn't Automatic Guilt

The District of Columbia Court of Appeals has vacated the weapons convictions of Marc Anthony Quarles, ruling that Metropolitan Police Department officers lacked the reasonable, articulable suspicion required under the Fourth Amendment when they stopped him after spotting what one officer believed was a handgun imprinted through his clothing. The decision, issued Thursday, sends the case back to D.C. Superior Court and marks another blow to how local police can justify street stops in a city where carrying a concealed handgun is now legal for licensed residents.

According to Tampa Free Press, the case began when Officers Zelesnick and Griffin saw Quarles walk past their parked cruiser and followed him after he entered and exited a nearby carry-out restaurant. The officers were not responding to any crime report and had no prior information about Quarles, per the same account. Officer Zelesnick, who said he had recovered around 100 firearms during his career, told the court he immediately perceived a magazine imprinting through Quarles's clothing and believed the rectangular shape was a handgun handle and magazine — though he acknowledged he did not know whether the item was actually a wallet or bag, and did not know whether Quarles held a concealed carry permit.

Officers Called Out, Then Chased Him Down an Alley

Officer Griffin called out “yo, my man, yo” multiple times as the officers approached, the outlet reports. Quarles then ran down an alleyway, and Griffin tackled him roughly 15 seconds later. Police recovered a handgun from Quarles's hip during the encounter, and he was subsequently arrested. Notably, officers saw no furtive waistband adjustments before the chase began.

At trial, Judge Jason Park denied Quarles's motion to suppress the weapon, ruling that the officer's visual identification combined with Quarles's flight showed consciousness of guilt. The appellate panel rejected that reasoning entirely. Associate Judge McLeese, joined by Judges Beckwith and Deahl, wrote that mere possession of a handgun without more no longer creates reasonable, articulable suspicion sufficient for an investigative stop, citing District of Columbia v. Heller and New York State Rifle & Pistol Ass'n v. Bruen as the governing precedent.

Court Says Flight Alone Doesn't Prove Guilt

The appellate court also found that Quarles's flight did not establish reasonable suspicion under the circumstances, noting he did not flee immediately upon seeing police. Judges recognized that innocent people may run to avoid unwanted or intimidating police confrontations, and the panel specifically acknowledged that racial dynamics and apprehension among African American men can provide a non-criminal context for flight. In other words, the court ruled Quarles had a reason other than consciousness of guilt to run.

That reasoning echoes a broader pattern in D.C. jurisprudence. Per The Heritage Foundation, prior D.C. Court of Appeals decisions have similarly considered a suspect's race and lived experiences with law enforcement when evaluating whether an encounter amounted to a seizure or why someone might choose to flee rather than stop.

A City Reshaped by Second Amendment Rulings

The ruling lands amid a rapid legal transformation of D.C.'s gun laws. The District once banned almost all handguns outright, a policy the U.S. Supreme Court struck down in 2008 when it ruled in District of Columbia v. Heller that the Second Amendment protects an individual's right to possess handguns for self-defense, according to SMU Scholar. Nearly a decade later, the D.C. Circuit's 2017 ruling in Wrenn v. District of Columbia forced the city to abandon its discretionary permitting system, and D.C. officials declined to appeal, per Justia's account of the case.

Today, D.C. provides a legal pathway for qualified residents to obtain concealed carry licenses. Under current Metropolitan Police Department regulations, applicants aged 21 and older can qualify by completing 16 hours of classroom instruction, 2 hours of range training, submitting residency proofs, and passing fingerprint background checks, according to the department's own guidance. Because thousands of District residents can now lawfully carry concealed handguns, the mere visual observation of a firearm-shaped object no longer proves unlawful possession — a shift the Court of Appeals leaned on heavily in the Quarles decision.

Legal Tension With the Supreme Court

The ruling also sits inside a live legal dispute between the D.C. Court of Appeals and the U.S. Supreme Court over how much weight flight should carry in reasonable-suspicion analysis. In Illinois v. Wardlow, decided in 2000, the Supreme Court held 5–4 that unprovoked flight upon noticing police in a high-crime area can justify a brief investigatory stop, according to Oyez. But this April, the Supreme Court issued a summary reversal in District of Columbia v. R.W., finding that D.C.'s appellate court had improperly used a “divide-and-conquer” approach that excised unprovoked flight and late-night context from its reasonable-suspicion analysis rather than weighing the totality of circumstances, per the Legal Information Institute.

The Quarles panel's reasoning — that flight alone did not establish suspicion given the circumstances — arrives just months after that rebuke, underscoring the ongoing friction between the two courts over how firearm-carry rights should reshape policing on D.C. streets. Pennsylvania's Supreme Court reached a similar conclusion in its 2019 Commonwealth v. Hicks ruling, holding that open or concealed carry alone cannot justify a Terry stop, according to The Federalist Society.

What Comes Next

With the handgun evidence suppressed and Quarles's weapons convictions vacated, the case now returns to D.C. Superior Court. The ruling comes as the city's court system already faces strain: public reports this month indicated the U.S. Attorney's Office for D.C. is short 90 attorneys and 60 investigators, while roughly 20% of D.C. judicial seats remain unfilled, according to reporting circulated by the Washington Post. Those staffing gaps compound the operational challenge for prosecutors and police navigating a legal landscape where, as the Court of Appeals put it, carrying a handgun in public is no longer presumptively illegal in the nation's capital.

Hoodline previously reported on the same appellate court's broader rollback of local firearm restrictions in a ruling striking down D.C.'s magazine limit, part of a pattern of decisions reshaping what police can and cannot treat as suspicious under a post-Bruen legal framework.