United States v. Davis, No. 18-2975 (8th Cir. 2019)Annotate this Case
The Eighth Circuit reversed the district court's grant of defendant's motion to suppress evidence found inside of a rental car in which defendant was the passenger. The court held that the officer acted on reasonable suspicion to extend the traffic stop and defendant was not unreasonably seized in violation of the Fourth Amendment. In this case, the officer found a loaded weapon in the car, and thus had probable cause to search the vehicle for evidence of criminal activity. Therefore, defendant had no standing to challenge the pretextual inventory search. Furthermore, because defendant lacked a reasonable expectation of privacy in the vehicle as a passenger, he could not assert a Fourth Amendment challenge to the vehicle search.