USA v. Stewart, No. 22-3014 (3d Cir. 2024)
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Appellant Gilroy St. Patrick Stewart was pulled over by Trooper George Tessitore for driving a vehicle with heavily tinted windows and a partially obstructed license plate, both violations of the Pennsylvania Vehicle Code. The United States Court of Appeals for the Third Circuit had to determine whether the officer unconstitutionally prolonged the traffic stop, thereby violating Stewart's Fourth Amendment rights.
Upon pulling over Stewart, Tessitore asked for his driver's license and the vehicle’s registration. Stewart produced an Ohio driver's license and a vehicle that was registered to a Hazel Sparkes of Baldwin, New York. Stewart claimed the vehicle belonged to his aunt. Tessitore then questioned Stewart about his travel plans. During the stop, Tessitore discovered that Stewart had a history of arrests, including a money laundering arrest made by the Drug Enforcement Agency. Tessitore also noted that Stewart was driving on I-80, a well-known drug trafficking corridor, and that there was an air freshener hanging from Stewart's rear-view mirror, often used to mask the smell of narcotics.
Stewart was subsequently charged with possession of five kilograms or more of cocaine with intent to distribute, after 20 kilograms of cocaine were found in a hidden compartment in his vehicle. Stewart moved to suppress the cocaine as the fruit of an unlawful search, a motion that was denied by the District Court.
Upon review, the Court of Appeals held that the officer had reasonable suspicion of criminal activity when he extended the length of the stop, due to a combination of factors including Stewart's evasive and inconsistent answers, the darkly tinted car windows, the car's registration to a third party, Stewart's prior arrests, his travel along a known drug corridor, and the air freshener in his vehicle. As such, the officer did not unconstitutionally prolong the traffic stop, and Stewart's Fourth Amendment rights were not violated. The Court affirmed the District Court’s order denying Stewart's motion to suppress evidence from the traffic stop.
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