United States v. Ryan, No. 11-2341 (1st Cir. 2013)Annotate this Case
A federal law enforcement officer made a lawful traffic stop of Appellant, but by the time the officer stopped Appellant, he and Appellant were outside the jurisdiction in which the officer was authorized to make arrests. The officer could see that Appellant was intoxicated and arrested Appellant. Appellant was subsequently charged with operating a motor vehicle under the influence, unsafe operation of a motor vehicle, and refusal to submit to a breath test. Appellant moved to suppress the evidence from his arrest on the grounds that the officer lacked the authority to arrest him. The magistrate judge agreed that the officer lacked statutory authority to arrest Appellant but refused to suppress the evidence because the arrest was not an unreasonable seizure. The district judge affirmed the magistrate judge's decision not to suppress the evidence. The First Circuit Court of Appeals affirmed, holding that Appellant's arrest did not constitute the kind of invasion of privacy that the Fourth Amendment prohibits.