United States v. Daniel Bonilla, No. 22-3006 (8th Cir. 2023)
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Defendant conditionally pleaded guilty to possession with intent to distribute fentanyl, in violation of 21 U.S.C. Sections 841(a)(1) and (b)(1)(A). The district court sentenced Defendant to a 132-month term of imprisonment and 5 years of supervised release. Defendant appealed the denial of his motion to suppress. Defendant argued that because he was arrested without probable cause when officers placed him in handcuffs during an investigative stop, the evidence seized from his backpack must be suppressed as the fruit of his unlawful arrest.
The Eighth Circuit affirmed. The court explained that here the officers had a legitimate concern that Defendant might try to run from the scene. When Detective Love asked for permission to search his suitcase, Defendant was calm and cooperative, giving the impression that it was “not a big deal.” However, as an additional officer started asking him questions, he showed physical signs of nervousness. Defendant already knew that the K-9 had alerted to his suitcase. Then, as Love was searching the suitcase, Defendant asked to go brush his teeth, which would have allowed him to leave the scene with his backpack, out of the officers’ sight. Given the change in Defendant’s demeanor over a short period of time, the perceived attempt to discard contraband outside the presence of the officers, and the other factors that aligned at least in part with drug-trafficking behavior, the officers had a legitimate concern that Defendant might try to flee.
Court Description: [Kelly, Author, with Loken and Shepherd, Circuit Judges] Criminal case - Criminal law. Officers had a legitimate purpose for handcuffing defendant during the Terry stop, as they had a legitimate concern he might try to flee the scene, given the change in his demeanor over a short period of time and other factors that were consistent with drug-trafficking behavior. Held: because placing defendant in handcuffs did not convert the investigatory stop into a de facto arrest, the seizure of evidence from defendant's backpack was not the fruit of an unlawful arrest and the district court did not err in denying defendant's motion to suppress.
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