United States v. Woods, No. 15-2837 (8th Cir. 2016)
Annotate this CaseDefendant was convicted of possession of a controlled substance with intent to distribute, possession of a firearm as a felon, and possession of a firearm in furtherance of a drug-trafficking crime. On appeal, defendant challenged the district court's denial of his motion to suppress evidence, alleging that the search of his vehicle violated his Fourth Amendment rights and that the officers violated his Fifth Amendment rights by questioning him without first obtaining a Miranda waiver. The court concluded that, based on the totality of the circumstances, the officer had reasonable suspicion that justified extending the traffic stop and that the roughly twenty-minute wait for the canine did not convert the otherwise lawful stop into an unreasonable detention. The court rejected defendant's argument that law enforcement officers were required to cease questioning him when he refused to sign a waiver form. In this case, defendant did not refuse to answer questions or tell the officers that he did not want to speak with them at any point during either interview. Accordingly, the court affirmed the judgment.
Court Description: Gruender, Author, with Smith, Circuit Judge, and Ketchmark, District Judge] Criminal case - Criminal law. The arresting officer had a reasonable suspicion that defendant was trafficking in drugs and this suspicion justified the extension of the traffic stop for roughly twenty minutes until a drug dog could arrive and conduct a sniff search; even though defendant refused to sign the Miranda waiver form, he knowingly, intelligently and voluntarily waived his Miranda rights by acknowledging that he understood them and by agreeing to speak to the officers and discuss his offense.
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