United States v. Hanel, No. 20-1020 (8th Cir. 2021)Annotate this Case
The Eighth Circuit affirmed the district court's denial of Defendant Hanel and Clark's motions to suppress all evidence obtained during a traffic stop. The court concluded that, at the time the officers initiated the traffic stop, they had grounds for reasonable suspicion that the vehicle lacked proper registration in violation of Nebraska law. In this case, although the officers cited the lane change as their reason for stopping the vehicle, they already had an objective basis to stop it when the first two NCIC searches failed to indicate proper registration.
The court noted that its holding should not be interpreted as justifying all warrantless vehicle stops based on ambiguous results from data searches. Rather, the court emphasized that its holding depends on the express factual findings that: (1) the NCIC database was not inherently unreliable; (2) the officers were competent in the use of their laptop; and (3) the officers were competent in accessing the NCIC database.