United States v. Bradley, No. 19-2003 (3d Cir. 2020)Annotate this Case
Pennsylvania Trooper Johnson stopped Bradley for speeding. Bradley admitted that his license was suspended. Johnson took Bradley to talk in the squad car. With a friendly demeanor, Johnson coaxed Bradley into admitting that he had just been sentenced to two and a half years in prison for “drugs.” After about 10 minutes, Johnson stated that he was going to give Bradley a warning ticket. Johnson later acknowledged that he would not have let Bradley leave and had, from the beginning, suspected criminal activity. Corporal Hoye arrived. Johnson asked Bradley whether there were any guns, marijuana, large sums of U.S. currency, heroin, or cocaine in the car. Bradley denied having those items. Johnson asked again, with Hoye standing next to Bradley. Flanked by state troopers, Bradley admitted he had cocaine. Johnson then recited the Miranda warnings. Johnson believed he had probable cause to search the vehicle. Bradley stated that “a lot” of cocaine was in the trunk. About a kilo of cocaine in a backpack was lying in the trunk. Bradley successfully moved to suppress his confession and the physical evidence.
The Third Circuit vacated in part and remanded for the district court to decide whether supplementation of the record is needed to decide whether the cocaine would have been inevitably discovered during an inventory search, and, if so, whether police department policy sufficiently cabined the scope of the officer’s discretion in conducting the inventory search such that the search of the backpack, a closed container, would have been lawful.