USA v. Henry, No. 21-20043 (5th Cir. 2022)
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Defendant was arrested and indicted on federal drug charges following the seizure of 400 grams of heroin 26 minutes into a traffic stop. At trial, Defendant unsuccessfully litigated a motion to suppress and then entered a conditional guilty plea. Defendant then appealed the denial of his motion to suppress.
The Fifth Circuit affirmed the district court's denial of Defendant's motion to suppress. The traffic stop leading to the discovery of the narcotics was justified at its inception because Defendant was speeding, driving on the shoulder of the road, and littered a cigarette out his window. The court also held that the length of the traffic stop was justified. While a traffic stop must be temporary and last no longer than necessary, upon the development of reasonable suspicion, officers can extend the stop. Here, three minutes into the stop the officer determined Defendant's license was suspended. The officer could have arrested Defendant at this point for driving on a suspended license. However, as the stop progressed, the officer developed reasonable suspicion that Defendant was involved in the sale of heroin, leading to the permissible extension of the stop.
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