United States v. Hanel, No. 20-1020 (8th Cir. 2021)
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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.
Court Description: [Grasz, Author, with Benton and Erickson, Circuit Judges] Criminal Case - suppression. During a traffic stop after observing an improper lane change, the passenger refused to identify himself, and there was no valid registration for the vehicle, officers requested a fingerprint identification machine and a drug dog. The drug dog indicated that narcotics were in the vehicle. Car was searched and the driver and passenger detained. Hanel and Clark move to suppress the evidence seized, arguing the lane change did not violate Nebraska law. The district court denied the motion to suppress, concluding the officers had reasonable suspicion that the car lacked proper registration and the officer's belief that the registration status justified the stop. After pleading guilty, Haney and Clark appeal the denial of the motion to suppress, challenging only the constitutionality of the initial stop. Because officers had objective basis to stop vehicle based on lack of registration, even if they cited lane change as reason and they later learned the vehicle was properly registered, the district court's denial of motion to suppress is affirmed.
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