United States v. Braddy, No. 19-12823 (11th Cir. 2021)Annotate this Case
Officer Sullivan pulled over Braddy on I-65 in Saraland, Alabama, after seeing Braddy react to the presence of his marked patrol vehicle and observing that Braddy’s vehicle’s license tag was obscured by bicycles. During the traffic stop, officers discovered cocaine in Braddy’s vehicle following two canine sniffs. Braddy was charged with possession with intent to distribute more than five kilograms of cocaine, 21 U.S.C. 841(a)(1), and conspiracy to possess with intent to distribute more than five kilograms of cocaine, 21 U.S.C. 846.
The trial court denied his motion to suppress, rejecting an argument that the reason for pulling Braddy over, a violation of an Alabama law requiring motor vehicle operators to keep their license plates plainly visible, did not provide probable cause because the statute did not apply to Braddy as a nonresident of Alabama. The Eleventh Circuit affirmed. Any mistake of law by Sullivan was objectively reasonable and the traffic stop of Braddy’s vehicle was based on probable cause. Sullivan did not unlawfully prolong the traffic stop. There was probable cause to search Braddy’s vehicle based on the reliability of the drug detection dogs’ alerts.