United States v. Morgan, No. 12-4043 (8th Cir. 2013)
Annotate this CaseDefendant was indicted for possession with intent to distribute five grams or more of methamphetamine. On appeal, the government challenged the district court's grant of defendant's motion to suppress evidence seized from his person and vehicle. The court concluded that police officers had reasonable suspicion to believe that defendant was engaged in criminal activity and a reasonable belief that defendant was dangerous; defendant's furtive gestures under his seat as the officers approached the vehicle gave them reason to believe that there was a weapon in the vehicle that defendant might access when the Terry stop ended and he was permitted to return to the vehicle; this objectively reasonable concern for officer safety justified the officer's immediate protective sweep under the driver's seat of the vehicle; because reasonable suspicion was established, the officer's search of the vehicle's interior was permitted even though the occupants had been removed from the vehicle; the officer was also authorized to search the lockbox he found in the vehicle, which was large enough to conceal a weapon; the limits of the Terry stop were not exceeded when defendant was removed from the vehicle and handcuffed; and consequently, because there was no unlawful arrest, the district court's rationale did not justify suppression of the evidence and statements. Accordingly, the court reversed and remanded.
Court Description: Criminal case - Criminal law. The district court erred in suppressing physical evidence and defendant's post-Miranda warnings to officers as the officers had reasonable suspicion to detain defendant under Terry and his furtive gestures under his car seat as officers approached gave them reason to believe there was a weapon in the car that he might access; the officer's objectively reasonable concern for their safety justified an immediate protective sweep under the driver's seat; officers were also authorized to search a lockbox they found in the car as it was large enough to conceal a weapon; officers did not exceed the valid limits of a Terry stop when they removed defendant from his car and handcuffed him while officers performed the protective search; defendant's arrest was not unlawful, and the evidence seized during the encounter was admissible; defendant's post-Miranda statements were admissible as he voluntarily and knowingly waived his right to remain silent.
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