United States v. Noonan, No. 13-1732 (8th Cir. 2014)
Annotate this CaseDefendant appealed the denial of his motion to suppress evidence after pleading guilty to possession of methamphetamine precursors. The court affirmed the denial of the motion to suppress the physical evidence found after the stop of defendant's car where the officer had reasonable suspicion for an investigative stop of defendant's vehicle considering the overtly-cautious driving, time of night, evasive maneuvers, and rash of recent burglaries. The court concluded that the public exception to Miranda v. Arizona applied to the officer's questions regarding what he might find in the vehicle because those questions were reasonably aimed at addressing the safety hazard posed by the manufacture of methamphetamine. Therefore, the court affirmed the district court's admission of the statements at issue.
Court Description: Criminal case - Criminal law. Taken in their totality, the facts observed by the police officer - overly-cautious driving, time of night, evasive maneuvers, and a rash of recent burglaries in the area - gave the officer reasonable suspicion for an investigative stop; the public safety exception to Miranda applied to the officer's questions regarding what he might find in defendant's vehicle because those questions were reasonably aimed at addressing the safety hazard posed by the manufacture of methamphetamine.
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