United States v. Beard, No. 11-3311 (8th Cir. 2013)
Annotate this CaseDefendant conditionally pled guilty to conspiracy to possess with the intent to distribute marijuana, reserving his right to appeal the district court's denial of his motion to suppress the marijuana. On appeal, defendant argued that the district court erred in crediting the state trooper's testimony over his at the suppression hearing because a video recording of the traffic stop contradicted the trooper's testimony. After reviewing the video, the court could not say that the district court clearly erred in concluding that defendant had a better view of the events than the camera in his patrol car, and consequently, deferred to the trooper's description of the incident. The court held that the district court correctly denied defendant's motion to suppress where, given the trooper's description of defendant's erratic driving, the trooper had an articulable and reasonable suspicion that defendant violated Arkansas traffic laws; the trooper had a lawful basis for stopping defendant's vehicle; and the trooper's search of the vehicle and seizure of the marijuana were lawful under the automobile exception because he smelled the raw marijuana immediately after defendant rolled down his car window. Accordingly, the court affirmed the judgment.
Court Description: Criminal Case - suppression. District court did not clearly err in concluding officer had a better view of events than the camera in the patrol car and consequently it deferred to officer's testimony of events; officer had an articulable and reasonable suspicion that defendant violated Arkansas traffic law and thus had a lawful basis for stopping defendant's car. Subsequent search and seizure was lawful under the automobile exception and the district court correctly denied the motion to suppress.
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