United States v. Stegall, No. 16-2549 (8th Cir. 2017)Annotate this Case
Defendant appealed the district court's order denying his motion to suppress after he was convicted of possessing an unregistered short-barreled rifle. Officers discovered firearms in defendant's vehicle after they responded to a report of a road rage incident where a driver brandished a firearm. The court concluded that the warrantless search of defendant's vehicle was reasonable under the second exception in Arizona v. Grant. In this case, officers reasonably believed defendant's vehicle might contain evidence relevant to his arrest for terroristic threatening because defendant confirmed he was the driver of the SUV and involved in the earlier road rage incident, defendant told the officers he "probably" had a firearm in his vehicle, the 911 caller positively identified defendant as the driver who brandished a gun at him during the reported road rage incident, and a witness observed defendant concealing something in the rear hatch of his SUV. The court, along with its sister circuits, have held the hatchback or rear hatch area of a vehicle was a part of the passenger compartment as long as an occupant could reach that area while inside the vehicle. Accordingly, the court affirmed the judgment.