United States v. Clark, No. 17-1125 (1st Cir. 2018)Annotate this Case
The First Circuit affirmed the judgment of the district court denying Defendant’s motion to suppress drug evidence found on his person during a traffic stop.
A law enforcement officer stopped a vehicle in which Defendant was a passenger for a traffic violation. On appeal from the denial of his motion to suppress, Defendant argued that the officer violated Defendant’s Fourth Amendment rights by unreasonably extending the duration of the traffic stop and that the district court erred in ruling that the inevitable discovery exception to the exclusionary rule applied to the drug evidence found during the resulting patdown search, which the government conceded was unlawful. The First Circuit affirmed, holding (1) the officer did not unlawfully prolong the traffic stop; and (2) the proper scope of a patdown search was exceeded in this case, but the district court properly applied the inevitable discovery rule.
The court issued a subsequent related opinion or order on January 12, 2018.