Skip to content
Name: United States v. Williams
Case #: 15-10008
Court: US Court of Appeals
District 9 Cir
Opinion Date: 09/20/2016

District court erred by suppressing evidence where police had (1) reasonable suspicion to stop defendant based on a reliable tip and the surrounding circumstances, (2) probable cause to arrest defendant for obstructing their attempt to obtain his identity, and (3) probable cause to believe that further evidence of drug dealing would be found in his vehicle. Jones called police and informed them that Williams, a known drug dealer, was asleep in a black Ford outside an apartment complex he did not live at in a high-crime area. Police arrived, blocked the Ford, and illuminated their "take down" lights. Williams tried…

View Full Summary
Name: People v. Nice
Case #: H041847
Court: CA Court of Appeal
District 6 DCA
Opinion Date: 05/26/2016

Officer's visual estimate that car was traveling 10 to 15 m.p.h. over the speed limit was enough to give him a reasonable suspicion to conduct a traffic stop. Officer Beretta stopped a white Chevy for speeding. He visually estimated that the car was traveling 35-40 m.p.h. in a 25 m.p.h. zone. After stopping the car, he arrested the occupants who appeared to be high on methamphetamine. A search of the car revealed drugs and firearms. Before their trial for drug and firearms offenses, the defendants moved to suppress the evidence found in the car on the basis that Beretta's visual…

View Full Summary
Name: People v. Steele
Case #: C077040
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/25/2016

Officer safety justified the detention of defendant in his vehicle to assure that he did not present a danger to officers while they approached and investigated a vehicle in front of defendant's vehicle. Officers observed two cars driving down a rural dead end road with no streetlights. They ran a records check on both vehicles and discovered that the lead vehicle's registered owner had a warrant out for his arrest. When the vehicles stopped at the end of the driveway, the officers activated their emergency lights. They approached the second car first out of concern that its occupant could ambush…

View Full Summary
Name: United States v. Magallon-Lopez
Case #: 14-30249
Court: US Court of Appeals
District 9 Cir
Opinion Date: 03/31/2016

The fact officer lied to motorist about the reason for a stop is irrelevant to assessing the reasonableness of the stop under the Fourth Amendment. An officer stopped Magallon-Lopez's car because it fit the description of a car DEA agents suspected of transporting drugs based on information obtained via a wiretap. The officer who stopped Magallon-Lopez lied and said he pulled him over for failing to signal before changing lanes. Thereafter, a drug detection dog arrived and alerted to the presence of drugs. Officers seized the car, obtained a warrant, and found pounds of methamphetamine inside. After his conviction for…

View Full Summary
Name: People v. Brown
Case #: S218993
Court: CA Supreme Court
District CalSup
Opinion Date: 08/06/2015

Under the circumstances of this case, defendant was detained where police stopped behind defendant's parked car and activated the patrol vehicle's emergency lights. A deputy sheriff investigating an emergency call reporting a fight in progress pulled his car behind Brown's parked vehicle and activated his emergency lights. The officer found Brown to be intoxicated and he was charged with felony driving under the influence. Brown moved to suppress evidence of his intoxication as the fruit of an unlawful detention. The trial court denied the motion, concluding that Brown had not been detained until the deputy observed that he was intoxicated…

View Full Summary
Name: United States v. Evans
Case #: 14-10024
Court: US Court of Appeals
District 9 Cir
Opinion Date: 05/20/2015

Traffic stop prolonged for a dog sniff and an ex-felon registration check, which were unrelated to the traffic violation, violates the Fourth Amendment unless the officer had independent reasonable suspicion to prolong the detention. A Nevada officer stopped Evans for making an unsafe lane change and following a vehicle too closely. After questioning Evans and conducting a check for outstanding warrants, the officer requested an ex-felon registration check, which took eight minutes to process. Evans was properly registered. The officer issued Evans a warning and told him "you're good to go." Before Evans could leave, the officer asked him…

View Full Summary
Name: Rodriguez v. United States
Case #: 13-9972
Court: US Supreme Court
District USSup
Opinion Date: 04/21/2015

Police violate the Fourth Amendment when they prolong a traffic stop beyond the time needed to handle the matter for which the stop was made in order to conduct a dog sniff. An officer pulled Rodriguez over for swerving his car onto the shoulder of the road then back into the lane. The officer ran a records check of Rodriguez and his passenger. After issuing Rodriguez a written warning, the officer asked if he would consent to a dog sniff of his car. Rodriquez refused. The officer ordered him out of the car and waited seven to eight minutes…

View Full Summary
Name: United States v. Camou
Case #: 12-50598
Court: US Court of Appeals
District 9 Cir
Opinion Date: 12/11/2014

Search of an arrestee's cell phone 80 minutes after his arrest does not fall within the search incident to arrest exception to the warrant requirement. Border patrol agents arrested Camou and his girlfriend after an undocumented immigrant was found in their truck. Eighty minutes later, without a warrant, agents searched Camou's cell phone for evidence of alien smuggling. Agents found images of child pornography. The U.S. Attorney did not pursue alien smuggling charges because Camou's case "did not meet prosecution guidelines." However, a grand jury indicted Camou for possessing child pornography (18 U.S.C. § 2252(a)(4)(B)). Camou moved to suppress the…

View Full Summary
Name: Heien v. North Carolina
Case #: 13-604
Court: US Supreme Court
District USSup
Opinion Date: 12/15/2014

An officer's objectively reasonable mistake of law may provide the reasonable suspicion necessary to justify a traffic stop under the Fourth Amendment. An officer pulled Heien and his companion over for driving with one broken brake light. During the stop, Heien consented to a search of his vehicle. The officer found cocaine and Heien was charged with attempted trafficking. The trial court denied his motion to suppress, and he pled guilty. On appeal, he argued that the stop was not valid because North Carolina law only required one working brake light, which he had. The North Carolina Supreme Court ultimately…

View Full Summary
Name: People v. Brown
Case #: D064641
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 04/22/2014
Subsequent History: Review granted 8/20/14: S218993

When a vehicle has already stopped on its own, police officer's activation of emergency lights on patrol car is not a seizure within the Fourth Amendment. After his motion to suppress evidence was denied, Brown pled guilty to driving with a BAC of .08% or greater (Veh. Code, § 23152, subd. (b)) and admitted DUI priors. He appealed the denial of his suppression motion. The evidence at the hearing showed that a 911 caller reported a fight in an alley was in progress and referenced a loaded gun. A sheriff's deputy arrived at the scene of the fight within minutes…

View Full Summary