United States v. Andres, No. 19-10823 (11th Cir. 2020)
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The Eleventh Circuit affirmed defendant's convictions and sentence for distribution of methamphetamine, conspiracy to distribute methamphetamine, and possession of methamphetamine with intent to distribute.
The court held that defendant failed to establish good cause sufficient to overcome the untimely filing of his motion to suppress. The court also held that the district court did not plainly err by denying defendant's motion to suppress where the officer had probable cause to stop defendant's vehicle for a traffic infraction because the vehicle was following too closely to another vehicle. Furthermore, the investigating officers' collective knowledge of the ongoing criminal investigation justified the stop of defendant's vehicle. Finally, the court held that there was no clear error in the district court's finding that defendant did not accept responsibility for purposes of USSG 3E1.1.
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