United States v. Salgado, No. 13-2480 (8th Cir. 2014)
Annotate this CaseDefendant appealed the denial of his motion to suppress after pleading guilty to distributing and possessing with intent to distribute a controlled substance, and to aiding and abetting that offense. A state trooper pulled over behind defendant's broken-down car and initially approached him to offer assistance. The court concluded that a reasonable person in defendant's position would have understood that a state trooper had legitimate reasons to monitor the situation without seizing the motorist; once defendant identified himself as the driver and admitted that he did not have a driver's license, the trooper had probable cause to issue defendant a citation for a traffic violation and was thus entitled to detain defendant; the trooper had reasonable, articulable suspicion sufficient to justify an investigatory stop, including a dog sniff, where, among other things, defendant was unable to identify his passengers and knew one of them only as "Homie," and the trooper was unable to match the name and date of birth that defendant provided to the law enforcement database; once this reasonable suspicion was developed, the trooper did not effect an unreasonable seizure by detaining defendant until another officer arrived with the drug-detection dog; and because defendant's hour-long detention before the dog-sniff was due to the remote location, not any lack of diligence or unnecessary delay by law enforcement, the court concluded that it was reasonable under the circumstances. The district court did not violate defendant's rights under the Fifth and Sixth Amendments by considering records of the drug-detection dog's field performance in camera without disclosing the records to him where evidence of the dog's training and certification was sufficient to establish the dog's reliability and thereby demonstrate probable cause. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal case - Criminal law. Officer's initial contact with defendant was a valid exercise of the community-caretaking function and did not amount to a seizure requiring probable cause or reasonable suspicion of criminal activity; when defendant admitted he did not have a driver's license, the officer had probable cause to detain him, ask him questions regarding his identity and determine his criminal history; based on the totality of the circumstances, the officer had reasonable suspicion that criminal activity was afoot, justifying an investigatory stop, including a dog sniff; delay in performing the dog sniff was caused by the remote location of the stop and was reasonable under the circumstances; district court did not err in denying defendant's request for access to the dog's performance records.
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