United States v. Jackson, No. 14-3756 (8th Cir. 2016)
Annotate this CasePlaintiff pled guilty to possessing marijuana with intent to distribute and then appealed the district court's denial of his motion to suppress. The court concluded that the drug dog was reliable and the affidavit in this case gave sufficient facts about the dog’s reliability. Moreover, all the other facts support probable cause: defendant was a licensed pilot for less than a month, he purchased the plane months before, he was flying a non-commercial aircraft a long distance at night, he deviated from his flight plan, and he displayed evasive behavior at the hotel. The court further concluded that, because there was probable cause that the aircraft contained evidence of a crime, the plane could be held until the warrant issued. Therefore, defendant could not have simply left on the aircraft, and his arrest in the hotel room and his subsequent detention awaiting the search warrant were lawful. Accordingly, the court affirmed the judgment.
Court Description: Benton, Author, with Murphy and Kelly, Circuit Judges] Criminal case - Criminal law. The affidavit submitted in support of a search warrant for defendant's plane established probable cause as it showed the drug dog was reliable and had alerted on the aircraft; in addition the other facts submitted in support of the warrant application - defendant's recent purchase of the plane and his limited flying experience, his diversion from his filed flight plan and his evasive behavior - buttressed the probable cause finding; because there was probable cause that the plane contained evidence of a crime, the plane could be held until the warrant issued.
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