United States v. Edwards, No. 17-1455 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction of conspiracy to distribute heroin and possession with intent to distribute heroin. The court affirmed the district court's denial of defendant's pre-trial motion to suppress evidence seized during a traffic stop and statements made to officers after his arrest, holding that law enforcement officers did not violate defendant's Fourth Amendment rights and there was no basis to exclude the disputed evidence. In this case, the officers had probable cause to believe defendant committed a drug trafficking offense and that evidence of the offense was contained in his vehicle. Furthermore, the drug dog's failure to alert on the car was relevant to the probable cause determination, but was not determinative. The court reasoned that police may consider other, pre-existing information in making the objective determination as to whether there was a fair probability that evidence of the crime was in the vehicle.
Court Description: Colloton, Author, with Gruender, Circuit Judge, and Reade, District Judge] Criminal case - Criminal law. Information provided by a confidential informant, together with corroborating evidence gathered during the investigation, established probable cause to believe defendant committed a drug trafficking offense and that evidence of the offense was contained in his vehicle; evidence seized in the search, as well as defendant's incriminating statements, held admissible; drug dog's failure to alert on the car was relevant to the probable cause determination, but was not determinative; police may consider other, pre-existing information in making the objective determination as to whether there is a fair probability that evidence of the crime is in the vehicle.
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