United States v. Sanchez, No. 18-1890 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence recovered during a traffic stop. The court held that the officer had reasonable suspicion based on several specific and interrelated facts to extend the stop. In this case, the officer saw an out-of-state truck with paper tags driving in the middle of the night; he discovered neither adult in the vehicle had a driver's license and the paper tags were expired; there was some confusion as to the name of the owner; the purported purpose for the trip was a two-to-three-day painting job, but no supplies were present other than one can of paint; he learned all of this after having his suspicion piqued by the fact that defendant and his partner gave different names; and he thought it unusual that an unlicensed driver would bring small children and an unlicensed partner/significant other with him for the midnight travel in the unlicensed vehicle for a short term out-of-state job.
The court also held that, absent a physical trespass and during an otherwise lawfully extended stop, an officer may look at the undercarriage of a vehicle without probable cause. Finally, the officer had probable cause and had a legal basis for the subsequent seizure of the black plastic bag located above a spare tire.
Court Description: [Melloy, Author, with Benton and Kelly, Circuit Judges] Criminal case - Criminal law. The circumstances present, including the late hour,defendant's lack of a driver's license, his inability to provide the name of his vehicle's owner and a credible explanation of the purpose of the trip, provided the officer with a reasonable suspicion that the vehicle was transporting contraband and permitted him to extend the traffic stop; absent a physical trespass and during an otherwise lawfully extended search, an officer may look at the undercarriage of a vehicle without probable cause; officer's observation of a black plastic bag through the underside of the truck, together with the other facts and circumstances, gave the officer probable cause to believe the bag contained contraband and a legal basis for the subsequent seizure of the bag. Judge Kelly, dissenting.
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