United States v. Coleman, No. 12-1400 (8th Cir. 2012)
Annotate this CaseDefendant conditionally pled guilty to being a felon in possession of a firearm. Defendant reserved the right to appeal the district court's denial of his motion to suppress evidence seized from his vehicle. Defendant also appealed his armed career criminal sentence enhancement. The court held that the district court did not err in overruling defendant's motion to suppress on the basis of lack of probable cause to stop him; there was reasonable suspicion to stop defendant; even if there was no reasonable suspicion, such short detentions were de minimus intrusions; the officer was not required to give Miranda warnings before questioning defendant; search of the motor home was conducted with probable cause and reasonable; and the district court did not err in applying the sentencing enhancement.
Court Description: Criminal case - Criminal law and Sentencing. Traffic violation provided probable cause for vehicle stop and the officer had an objectively reasonable basis for believing defendant had violated the applicable statute by crossing the fog line; officer could ask defendant about drug use in order to eliminate drug use as a possible cause for the traffic offense, and defendant's dishonesty about his criminal history gave the officer grounds to prolong the stop and extend the questioning; district court did not err in finding defendant was not required to give defendant Miranda warnings before questioning him; defendant's statement that there was marijuana in his motor home gave the officer probable cause to search the vehicle for drugs, and a firearm found during the drug sweep was properly seized; no error in sentencing defendant as an Armed Career Criminal.
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