United States v. Williams, No. 19-1827 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence obtained from the search of his vehicle. The court held that the officers lawfully continued their investigation after they determined defendant was not carrying a gun because, during the pat down, defendant admitted that he had threatened to shoot a woman. In this case, the officers' request for defendant's identification was a reasonable and lawful extension of their initial investigatory stop. The court also held that the officers then had probable cause to search defendant's vehicle because one of the officers smelled marijuana when defendant opened the car door.
Court Description: [Gruender, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Criminal case - Criminal law. The police officers lawfully continued their investigatory stop as defendant admitted threatening the reporting party, and the officers had at least a reasonable suspicion defendant had committed the Iowa offense of harassment; officers had sufficient suspicion to justify an expansion of the investigation by asking for ID; officers had probable cause to search defendant's vehicle as they smelled marijuana when he opened his car door to retrieve his ID.
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