United States v. Linnell, No. 23-2121 (8th Cir. 2024)
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In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Mary Linnell appealed her conviction for possession with intent to distribute a controlled substance. The case arose after a traffic stop during which law enforcement officers found methamphetamine, cocaine, and drug paraphernalia in the vehicle in which she was a passenger. Linnell moved to suppress the evidence, arguing that the patrol officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The district court denied the motion, and Linnell entered a conditional guilty plea, preserving her right to appeal the suppression ruling. She was sentenced to 92 months’ imprisonment with 5 years of supervised release to follow.
On appeal, Linnell contended that the district court erred in denying her motion to suppress, asserting that the officer lacked probable cause or reasonable suspicion to conduct the traffic stop. The appellate court disagreed, ruling that the district court did not clearly err in finding that the officer observed three traffic violations (running a stop sign, following another vehicle too closely, and speeding), and therefore had probable cause to conduct the traffic stop. The court gave deference to the lower court's credibility determination of the officer's testimony, noting that the officer had several years of experience and had been involved in hundreds of traffic stops. The judgment of the district court was affirmed.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Gruender, Circuit Judge] Criminal case - Criminal law. The district court did not err in denying defendant's motion to suppress drugs and drug paraphernalia found in a vehicle in which she was a passenger, as the district court did not clearly err in finding that the vehicle had violated three traffic laws or that there was probable cause to conduct a traffic stop on any of those three bases.
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