United States v. James Rutledge, No. 22-1708 (8th Cir. 2023)
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Defendant entered a conditional plea of guilty to conspiracy to distribute a controlled substance and possession of a firearm. He reserved the right to appeal the denial of his motion to suppress drugs and a gun seized from his rental vehicle after a traffic stop and incriminating statements he made later that day. On appeal, Defendant argued the district court erred because police officers did not have an objectively reasonable basis to believe he committed a traffic violation and then unconstitutionally expanded the stop while a drug dog sniffed the exterior of the vehicle.
The Eighth Circuit affirmed. The court explained that here, given the undisputed facts regarding the length of the stop, particularly its short duration, and the reasons given for the time it took to almost complete the purpose of the stop before the narcotics dog alerted to the rear of the driver’s side, the district court did not err in concluding that the Sergeant did not unlawfully prolong the stop before the dog alert gave the officers probable cause to arrest Defendant and search the vehicle. Further, the court held that there was no Fourth Amendment violation before Defendant made incriminating statements after being given Miranda warnings. Thus, the district court properly rejected his argument that the statements should be suppressed as fruit of a poisonous tree.
Court Description: [Loken, Author, with Erickson and Kobes, Circuit Judges] Criminal case - Criminal law. The officers had an objectively reasonable basis to make a traffic stop after defendant failed to make a complete stop at a stop sign; the state trooper's conclusion that the relevant South Dakota statute required drivers to make a complete stop at two stop signs controlling different portions of a complex highway interchange was not unreasonable; the traffic stop was not unlawfully prolonged to permit a drug dog sniff. [ March 02, 2023 ]
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