defense brief and for officer squires agreed that there was no grand additionally this court in williams citing jail at footnote one in williams distinguish the concealed gun in jail from the branching that heard bullets there wasn't rain to shame on that points there wasn't an emergency the question then is was there a crime that was specified by the nine one one call or in the defendant brief defendant goes through about six different statutes that could be reason predicates for a crime being committed by possessing a firearm the government proposes a seven but in the defendant's reply brief even there he recognized there there is certainly nothing improper in fact a b and b are responsible the of the police not to respond to this nine one one call right i mean and you're not arguing and i know that's entirely correct in fact so they don't do for the watson opinion in judge your focus then be on you know what what went down what officer squires you know saw and perceived and whether that created reasonable suspicion or not as well as officer fosdick yes but the first point is an important one because the government's has maintained that there is an emergency laying it out in terms of how the case law of works on terms of firearms is an important point to make the second point that we want to make is that it was a generalized search now it's importance in this case that police are responding not to a car like an watson where everybody is located in one single place they're all responding to a navarette call where it's one car it's going down a road and then there's not a bunch of traffic they're not responding two scenario where there is a single car that triggers magnetic sensors and there are traveling down isolated road this is a open parking lots in a on private property the caller describes a group of people that area itself has areas for ingress and egress the people who are on the property can go through the back of the property into a trailer park the police agree that they are not its officer squires agrees x the suppression hearing that police were not trying to stop people from going out of the parking lot or stopping them from coming into the parking lot that there is no control people whether the going into and out of the partment building that also plays a factor in terms of how do you understand the stunnel one call and who are the of the people that you dare he knows he's a convicted felon he sees mr adair trying to move away from him and then he notices what appears to be a gun in his front pocket why wouldn't that that court said that when you're doing a results when you're doing the now series will suspicion you do it's tell you the circumstances analysis that the police are not relieved from the duty of doing an investigation what's happening there and there were facts for them to determine about whether or not people actually did live there whether the people would guess that wasn't necessary once the officer recognized mr adair and knew he was a convicted felon that makes his gun possession awful and he can move in at that point your honor it's before mr adair was stopped before he was seized before he was searched the police conducted searches of two other people ok so it doesn't matter we're talking about the search of your client fallon he has what looks to be a gun in his pocket that's a muffle i guess agree or hundred the issue is whether that nine one one call point it picked out a particular person and the evidence before the courts in i think that's what the it wasn't that what officer squires was doing i mean he responded to the nine one one call he shows up he sees this group of folks he's approaching like hey what's going on here you know and then the reasonable in other words i don't know what the content of he should conduct an investigation your honor so there's a the number one call comes in there are five people that respond five officer four or five officers and the one the officers had exactly the same behavior is absolutely contrary to that so what is it you think officer squires should have done in terms of additional investigation before patting down your client i don't think that he should been able to  that the person was using their pockets and he saw a bald that appeared to be a gun that's what he testified to and the district court found him credit was in a group of ten people but that matched the description of the caller who said that the gun was in his pocket good afternoon your owners paul morris on behalf of the united states your honor's questions really get to the heart of this what should the bloomington police department have done in this case they did that what they were supposed to do a ten forty seven at night  responding to a nine one one call or it was willing to give her name and she showed up and they were investigating crime they were concerned about what the nine one one caller was concerned about was the gun the displayed gun a gun that just wasn't in the pocket she knew it was a black gun and walking by almost contemporaneously she's looking at this gun she's calling nine one one in minutes later the bloomington police department is there equally concerned eyes open you know observation of their investigation of what else is going on and so yes a rival officer squiers is looking for that individual matching the suspect with the gun but then he sees somebody he knows he sees mr adair there's a couple things that's important about that as your honour's have already pointed out he's a known felon felon prohibited from having a firearm also corroborating the nine one the thrust really of the the clutching a circumstance is nine one one caller says the gun is in the pocket he's approaching the defendant and the defendant is trying to object that can be consistent with a gun and so that the taliban those circumstances mr morris one of the for discussion purposes and you can you can challenge the premise of this if you'd like let's assume that the photos are clear enough that there is not a great footy just assume that ok how does your analysis how does your analysis proceed from there it's it could question just better because it's not just a hypothetical  district court takes that as its alternative ruled it says let's take this footy off do we still have reasonable suspicion in the ruling is yes and the way that it arrives at that  conclusion is it contrasts destroyed there with the other people in that group you have descriptions as government exhibit of provides of the officers police are part of whatever else is wearing out the testimony everyone else wearing pink tops and t shirts you've got another individual that's wearing and the only one wearing a long sleeved shirt and so arriving there and we make the point a legal point of reasonable mistakes the facts reasonableness that touchstone of the fourth amendment right that this was sent i mean this this whole hoodie issue is what dominated the suppression hearing and  clear that there wasn't a hoodie and your point that if the picture was crystal clear which the government doesn't agree that it is but if it was that the district court was still reasonable you calling the pictures from the squad car as being reliable and then two lines down the picture from the squad car as being unreliable i just want to state where did the pictures come from officer squires created these pictures by turning on his squad car camera it is a low quality squad car camera taken from up above and you've got somebody that's a lot higher quality than one at the channel which the government relied on below and so if i could just make sure that we're all in the same page those are from the exact same camera but one from the jail is from the car that one's of him seated in the back of the car though it captures something outside the car that is right in the reason for the government selecting that image it's really the only image that we have that is similarly situated to help squires saw adair upon walking up to the group it's him standing not seated the back of his neck which you agree there's no hoodie there yet i would agree with what defense counsel responded to the district court when really asked that question what does that mean and you know in in that response on page ninety seven and i think it's a fair response when asked well what are we doing you know there's just because the pictures in your mind show there's no thirty what does this mean and defense counsel mr shandor says we believe so you're on the other hand so it's either there is a hoodie there for whatever reason there is some principle that the camera couldn't pick it up either when he's leaning down or looking up that there are no conclusion i can't see a hoodie there i want to go ahead finish i was just going to say that when he looked at though the picture of mr adair standing on the outside he said he saw fabric a thin fabric that was consistent with a hoodie so he  competing ways that he can go and so under the clear standard even if it was just those two images he should be entitled to that deference in making his decision along with the testimony of officer scars but that's not what he did he also included an inventory report or another officer had mr adair take off his clothing and then wrote down great put it this is another person entirely attached from officer squires and officer squires is used wrong he's just simply wrong there is no who you know full stop there's ambiguity with the property log and what have you but it's as clear as day there's nobody and then i thought what you do is you would have pain your your argument on the alternative theories me if they did that that's where i thought you were going to go because i think the pictures are i mean it looks to me like it's a long sleeved t shirt of some kind and we make that argument you still stand by th argument as the ultimate ruling of the a district court that he's as i stated the only one with a long sleeve shirt he's the only one that as they walk out that is acting of a civil e he's the one with a pocket in his pockets bulging in the same location as the nine one one caller said the gun was and so i mean but the tally of of those circumstances along with also knowing that he doesn't live there knowing that this is a higher crime neighborhood all of those acting suspiciously he sees the group for operating the nine one one call or he sees the defendant the defendant matches the suspect even taking the hood of footy out with a long sleeve shirt everyone else has got to think cops are t shirts he knows he's a felon you know we can't have a gun but there is a basis and lastly the pockets all of those factors that i just listed are what the district court took into consideration and still stick even without the subject any questions that you may have thank you thank you your honor's the number one callers ascriptions important because that is what prevents the search becoming a generalized search once that this if it's just a short black male anybody in the group gets searched and that's in fact what happens you court was clear air how does that affect the rest of the officers testimony that affects was also his testimony because in the way that then the only thing that's left of the nine one