United States v. Clayton, No. 23-30231 (5th Cir. 2024)
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Courtney D. Clayton was indicted on one count of possession with intent to distribute heroin, fentanyl, and cocaine. As part of a three-month drug trafficking investigation, officers conducted video surveillance of Clayton's home and placed GPS tracking devices on two vehicles associated with him. Based on the surveillance and information from a reliable confidential informant, officers obtained search warrants for Clayton's home and one of his vehicles. However, before the warrants could be executed, officers observed burglars break into Clayton's home. Believing that evidence of drug trafficking may have been stolen, officers continued their investigation for another two weeks before seeking a new warrant for Clayton's residence. The officers did not renew their search warrant for the vehicle.
The district court denied Clayton's motion to suppress evidence found in his vehicle and his incriminating statement to law enforcement. Clayton contended that the search warrant of the vehicle had become stale, and that officers did not have probable cause to arrest him. He also argued that the Government failed to show that officers advised him of his constitutional rights pursuant to Miranda v. Arizona. After the denial of his motion to suppress, Clayton pleaded guilty but preserved his right to appeal the denial of his motion to suppress.
The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the search of Clayton's vehicle was proper under the automobile exception to the Fourth Amendment, which allows a warrantless search of a readily mobile vehicle when law enforcement has probable cause to believe the vehicle contains contraband or evidence of a crime. The court also found that Clayton failed to properly invoke his Fifth Amendment right to silence, as his indication through body language that he did not wish to speak to officers did not constitute a "simple, unambiguous statement" invoking his right to remain silent.
This opinion or order relates to an opinion or order originally issued on April 4, 2024.
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