United States v. Norville, No. 21-2493 (7th Cir. 2022)
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The Seventh Circuit affirmed the judgment of the district court denying Defendant's motion to suppress without holding an evidentiary hearing, holding that the district court did not abuse its discretion by denying an evidentiary hearing.
A law enforcement officer stopped Defendant while he was riding a motorized bicycle and arrested him under the theory that his bicycle was a motor vehicle requiring a license. During the arrest, police searched Defendant and found various drugs and drug paraphernalia. Defendant filed a motion to suppress, arguing that the government needed to establish probable cause that he was driving a motor vehicle on a revoked license. The district court summarily denied the motion. The Seventh Circuit affirmed, holding that the evidence established that the arresting officer had probable cause to believe that Defendant rolled past a stop sign, which independently supported Defendant's arrest.
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