United States v. Williams, No. 15-10008 (9th Cir. 2016)
Annotate this CaseThe government appealed the district court's grant of defendant's motion to dismiss evidence of the crack cocaine in his pockets and the firearm in his vehicle. The court concluded that, based on the totality of the circumstances surrounding the stop, the officers had reasonable suspicion to briefly detain defendant and the district court erred in concluding otherwise; the officers had probable cause to arrest defendant and performed a valid search incident to arrest of defendant's person - which lawfully extended to the insides of defendant's pockets - after apprehending defendant for obstruction under Nevada Revised Statute 171.123; the court rejected defendant's contention that the government waived its argument that the officers had probable cause to arrest him for violating the Nevada statute; the government, having advanced its probable cause theory before the district court, is able to make a more precise argument on appeal as to why the officers had probable cause; and, in this case, the officers had probable cause to believe that evidence of contraband would be found in defendant's vehicle. Accordingly, the court reversed and remanded for further proceedings.
Court Description: Criminal Law. The panel reversed the district court’s order granting a motion to suppress evidence of crack cocaine in the defendant’s pockets and the firearm in his vehicle. The panel held that police officers had reasonable suspicion to conduct an investigatory stop based on the information they possessed and the reliability of a telephone tip. After the initial stop, the officers developed probable cause to arrest the defendant because he obstructed them in their attempt to enforce Nevada Revised Statute § 171.123, which dictates that police officers may detain a suspect whom the officers have reasonable suspicion has committed, is committing, or is about to commit a crime, in order to obtain that individual’s identity. The panel held that the government did not waive its argument that the officers had probable cause to arrest the defendant for violating § 171.123 where before the district court the government argued generally that the officers had probable cause to arrest him because he ran. The panel held that the officers conducted a valid search incident to arrest when they searched the defendant’s pockets and found crack cocaine. The panel further held that the officers lawfully searched the defendant’s vehicle because, under the totality of the UNITED STATES V. WILLIAMS 3 circumstances, they had probable cause to believe that it contained contraband or evidence of drug dealing. The panel remanded the case for further proceedings.
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