United States v. Gastelum, No. 20-3451 (8th Cir. 2021)Annotate this Case
The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence from a warrantless search of a vehicle. In this case, a state trooper stopped defendant's rental car for a traffic violation and conducted a warrantless search of the trunk where the trooper found over 15 kilograms of a mixture or substance containing cocaine.
Considering the totality of the circumstances, the court concluded that the trooper had reasonable suspicion to extend the stop where numerous facts alerted the experienced officer that criminal activity was afoot. Given the friendly atmosphere, rapport, and conversation that had developed between the trooper and defendant, coupled with defendant's characteristics, demeanor, and responses throughout the encounter, the court concluded that the district court did not clearly err in finding defendant voluntarily consented to the search.
Court Description: [Erickson, Author, with Loken and Kelly, Circuit Judges] Criminal case - Criminal law. The state trooper did not unreasonably extend the traffic stop as he had developed a reasonable suspicion that criminal activity was afoot; the district court did not err in finding, on this record, that defendant had consented to the search of his vehicle. Judge Kelly, dissenting.