United States v. Wright, No. 15-3237 (8th Cir. 2016)
Annotate this CaseDefendant entered a conditional plea of guilty to a drug trafficking charge, and then appealed the denial of his motion to suppress evidence seized during and after a search of his vehicle. The court concluded that defendant lacks standing to challenge the entry into the parking lot of the apartment complex because he did not have a reasonable expectation of privacy in that area. Therefore, the court need not address whether the officers' entry into the parking lot was lawful. The court explained that the uniformed officer’s act of shining a spotlight on defendant's car was not a seizure, and defendant does not claim that the officer effected a seizure by blocking defendant's SUV with the squad car. Once the uniformed officer detected an odor of marijuana coming from defendant's person, the officer had probable cause to arrest defendant and, a fortiori, reasonable suspicion to detain him for further investigation. In any event, the police had ample reasonable suspicion to justify an investigative stop of defendant in the parking lot. In this case, the smell of burnt marijuana and the presence of a marijuana cigar in plain view through the window were sufficient to justify a search for drugs. Finally, the court concluded that it is permissible to search an arrestee's person - here, defendant's pockets to obtain a key to the SUV - incident to an arrest. Accordingly, the court affirmed the judgment.
Court Description: Colloton, Author, with Melloy and Shepherd, Circuit Judges] Criminal case - Criminal law. Defendant lacked standing to challenge the police officers' entry into the parking lot of an apartment complex as he had no reasonable expectation of privacy in the area as he did not own or live at the property; officer's action in shining a spotlight on defendant's car was not a seizure; once an officer detected the smell of marijuana on defendant's person, the officer had probable cause to arrest him and, a fortiori, reasonable suspicion to detain him for further investigation; smell of burnt marijuana and the presence of a marijuana blunt in plain view in the vehicle were sufficient to justify a search for drugs; seizure of a key to the car from defendant's pocket was a lawful search incident to arrest.
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