United States v. Correa, No. 10-3504 (8th Cir. 2011)
Annotate this CaseDefendant was arrested and indicted for possession with intent to distribute over five hundred grams of methamphetamine. At issue was whether the district court erred in granting defendant's motion to suppress evidence of the methamphetamine and statements he made after its discovery. The court held that the district court erred in holding that the conversation between a state trooper and defendant on the bus was a detention subject to Fourth Amendment protection where a reasonable person in defendant's position would have felt free to end the conversation with the state trooper. The court also held that the district court erred in holding that defendant did not voluntarily consent to the state trooper's search of his jacket where defendant indicated that he understood the state trooper's questions and when asked specifically about searching the jacket, defendant replied "Yes" and handed over the jacket to the state trooper. The court further held that the Fourth Amendment was not violated by the state trooper's investigative detention of defendant, including handcuffing him and removing him from the bus, or by opening the suspicious containers which revealed a large amount of what proved to be methamphetamine. There was then probable cause to arrest defendant. Accordingly, the order of the district court was reversed and vacated and the case remanded for further proceedings.
Court Description: Criminal case - criminal law. A reasonable person in defendant's position would have felt free to end a conversation with officers and the district court erred in holding that defendant's conversation on a bus with officers was a detention subject to Fourth Amendment protection; the district court also erred in finding defendant did not voluntarily consent to a search of his jacket; Fourth Amendment was not violated by officer's investigative detention of defendant, including handcuffing him and removing from the bus, or by opening the suspicious containers which revealed a large amount of methamphetamine; there was then probable cause to arrest defendant; suppression order reversed and case remanded for further proceedings.
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