Last month, the U.S. Court of Appeals for the Second Circuit issued its decision in United States v. Walker, 965 F.3d.180 (2d Cir. 2020), reversing the district court's denial of Jaquan Walker's motion to suppress statements made and narcotics discovered during a search incident to arrest. In an opinion written by Circuit Judge Rosemary S. Pooler and joined by Circuit Judges Guido Calabresi and Susan L. Carney, the court held that the officers lacked an objectively reasonable belief that Walker had participated in criminal activity because their stop was based on Walker's alleged match to a photograph that "provided little meaningful identifying information to the police besides the race of a suspect." In finding this justification to be "woefully short of what the Fourth Amendment requires[,]" in addition to being based on "impermissible and manifest stereotyping, which c[ould not] be characterized as merely negligent conduct," the court further held that the narcotics and statements discovered as a result of the search were insufficiently attenuated from the unconstitutional stop and therefore inadmissible.