Redd v. State, 2026 Md. App. LEXIS 806 (Md. Ct. App. 2026)

The Maryland Appellate Court reversed the denial of a suppression motion based on an unlawful stop, finding that “sole possession of a firearm, without additional circumstances that indicate illegal possession or other involvement in criminal activity, cannot justify a stop.” The court further stated, “Upon considering decades of case law and federal and state supreme court precedent, we determined that ‘[t]he mere possibility that a person with a gun might not have a valid license or otherwise may be restricted from possessing a gun is not enough to establish reasonable suspicion for a seizure. Our holding clarified that for stops to be justified on possession of a gun, “police must have reasonable suspicion that the person is possessing the gun illegally.'”