United States v. Soderman, No. 19-2879 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence obtained from his vehicle. Defendant conditionally pleaded guilty to possession with intent to distribute controlled substances and possession of a firearm in furtherance of drug trafficking.
The court held that the state trooper's discovery that defendant's driver's license had been suspended justifiably extended the lawful scope of the traffic stop because of defendant's legal inability to remove the vehicle from the scene and the consequential need for a licensed driver or a tow truck to do so; officers had probable cause to believe that defendant's car contained evidence of trafficking while the trooper was addressing the issue of defendant's suspended license and related vehicle removal; and the automobile exception to the warrant requirement permitted the officer to conduct a warrantless search of defendant's car following its removal from the scene. Finally, defendant was not in custody during the traffic stop and the district court properly denied defendant's motion to suppress his unMirandized statements.
Court Description: [Wollman, Author, with Kelly and Stras, Circuit Judges] Criminal case - Criminal law. State trooper's discovery during a traffic stop that defendant's license had been suspended justifiably extended the lawful scope of the traffic stop because of defendant's legal inability to move the vehicle and the need to obtain either a licensed driver or a tow truck to do so; officers had probable cause to believe defendant's vehicle contained evidence of drug trafficking; the automobile exception to the warrant requirement permitted the officer to conduct a warrantless search of the car following its removal from the busy highway where the stop was conducted; defendant was not in custody during the traffic stop and his statements, which were made without Miranda warnings, were admissible.
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