Louisiana v. MiguelAnnotate this Case
Defendant Melvin Miguel was driving a vehicle that was stopped because it had a cracked windshield. Defendant had been driving with a suspended driver’s license and a fraudulent license plate. In addition, he admitted smoking marijuana. Before asking defendant to exit his vehicle, a detective scanned the interior and noticed an orange prescription bottle, with the name on the label peeled off, sitting in the broken driver’s side door handle. Defendant and his passengers disclaimed ownership of the bottle. Defendant exited the vehicle, was handcuffed and Mirandized, and placed inside a police vehicle. The detective then retrieved the pill bottle, opened it, and discovered five Hydrocodone pills. Defendant was arrested and charged with possession of a controlled dangerous substance, and cited for several traffic violations. Defendant moved to suppress the evidence found in the bottle on several grounds, including that the pill bottle was not immediately apparent as contraband to justify a warrantless search and seizure. The district court denied the motion to suppress after conducting a hearing and reviewing the detective’s body camera video. The court of appeal found the district court erred in denying defendant’s motion to suppress. The Louisiana Supreme Court concluded the appellate court erred, reversed its holding and affirmed the trial court.