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Name: United States v. Nava
Case #: 03-50364
Court: US Court of Appeals
District 9 Cir
Opinion Date: 04/08/2004
Subsequent History: Cert. den. 11/1/04

A motorist who was briefly handcuffed after being stopped at the border was detained but not arrested. The defendant moved to suppress the fruits of a search conducted at the Mexican border on the ground that it was non-routine and not justified by reasonable suspicion. Relying on the recent United States Supreme Court decision in United States v. Flores-Montano (2004) 541 U.S. __, the court rejected this argument because border searches do not require reasonable suspicion. The defendant also moved to suppress his postarrest statements on the ground that they were the fruit of an unlawful arrest, because the detaining officers asked him to exit his vehicle, handcuffed him briefly, and escorted him to a secondary waiting area while his truck was being searched. The Ninth Circuit held that the brief handcuffing did not transform this from a routine border detention into a custodial arrest, and his subsequent statements were thus not the fruit of an unlawful arrest.