"The government bears the burden of proof in justifying a warrantless search or seizure." United States v. McGee, 736 F.3d 263, 269 (4th Cir. 2013), citing Welsh v. Wisconsin, 466 U.S. 740, 749–50 (1984). In this case, the justification for the traffic stop was that Petitioner was speeding, a conclusion reached by the police officer based on a technique called "pacing." The issue in this Petition is whether an officer's invocation of pacing, without any ability to show how he was trained to use such a technique or why it was a reliable estimate of speed, satisfied the Government's burden of justifying the warrantless traffic stop in this case.

Whether an officer's invocation of 'pacing' as a basis for a traffic stop, without any ability to show how he was trained to use such a technique or why it was a reliable estimate of speed, satisfied the Government's burden of justifying the warrantless traffic stop