United States v. Esquivel-Rio, No. 12-3141 (10th Cir. 2013)
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A Kansas State Trooper monitoring traffic along I-70 spotted a minivan driving with a temporary out-of-state license tag. He called the tag in to dispatch to check its validity. When the dispatcher returned a "negatory on record, not returning," the trooper stopped the minivan. After receiving permission to search the vehicle, the trooper found over a pound of methamphetamine in a secret compartment inside the passenger area. Defendant was arrested, tried and convicted on federal drug charges. Defendant moved to suppress evidence of the drugs found in the van claiming the trooper lacked probable cause to stop him. The Tenth Circuit and other courts have regularly upheld traffic stops based on information that the defendant's vehicle's registration failed to appear in a law enforcement databases. But in this case, the database's reliability was called into question. When the trooper asked about the minivan's temporary tag, the dispatcher replied not only that the tag yielded a "no return" response from the queried database, adding that "Colorado [the out-of-state tag in question here] temp tags usually don't return." Without more than the database query, defendant argued the trooper lacked probable cause to stop him. The Tenth Circuit found that the district court failed to engage in an analysis of the evidence that was presented at trial that called the database into question. Accordingly, the Court reversed the conviction and remanded the case back to the district court for further proceedings.
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