Law School Case Brief
United States v. Chartier - 772 F.3d 539 (8th Cir. 2014)
An officer may detain the occupants of a vehicle while completing routine tasks related to the traffic violation, such as asking for license and registration or inquiring about the occupants' destination, route, and purpose. If during the course of completing these routine tasks, the officer develops reasonable suspicion that other criminal activity is afoot, the officer may expand the scope of the encounter to address that suspicion. In determining whether reasonable suspicion exists, courts look at the totality of the circumstances, and this process allows officers to draw on their own experience and specialized training to make inferences from and deductions about the cumulative information available to them that might well elude an untrained person.
On Dec. 7, 2012, Officer Erik Naaktgeboren of the Hiawatha Police Department was conducting routine patrol when he observed a blue Mercury Grand Marquis. After running the vehicle's license plate, he learned that the registered owner did not have a currently valid driver's license. It was dark, snowing, and misting. From his location behind the Grand Marquis, Naaktgeboren was able to see two heads above the seats' headrests, but the two-lane road he was on prevented him from pulling up next to the vehicle to determine whether the driver was the registered owner. Naaktgeboren initiated a traffic stop and approached the vehicle. A woman was in the driver's seat. While speaking with her, Naaktgeboren noticed a bottle of muriatic acid in the backseat and a Walmart bag and package of airline tubing tucked under the front passenger's leg. Because Naaktgeboren had been trained and certified by the Drug Enforcement Administration as a clandestine laboratory technician for dismantling and processing methamphetamine labs, he recognized the acid and tubing as items regularly used in manufacturing methamphetamine. After checking the occupants' identification cards, he identified the driver as Aubree Sivola and the passenger as defendant Adam Chartier. Naaktgeboren asked Sivola what they had purchased at Walmart, and she replied that they had not purchased anything there. This response seemed suspicious to Naaktgeboren, since he had seen a Walmart bag in the car, so he began to inquire about whether there were any illegal drugs in the car and indicated that he would be walking his drug-detection dog around the vehicle. Sivola then consented to a brief pat-down and showed Naaktgeboren her pockets. By then, dispatch had informed Naaktgeboren that Chartier had a prior incident on his record involving assault with a weapon. Naaktgeboren requested that Chartier step out of the vehicle and noticed bulges in his pockets when Chartier did so. Although Chartier refused to consent to a protective search, Naaktgeboren proceeded to pat him down. During the pat-down, Naaktgeboren felt a package of hypodermic needles in Chartier's pocket and asked him to remove the package and place it on the trunk of the Grand Marquis. Naaktgeboren then walked his drug-detection canine, Reso, around the vehicle. Reso alerted at the passenger-side door. Naaktgeboren searched the vehicle and did not find any contraband. Naaktgeboren then searched Chartier's person, notwithstanding Chartier's renewed refusal to consent to the search. Naaktgeboren seized several small plastic baggies that contained methamphetamine, a yellow drill bit case with pseudoephedrine pills in it, and a pipe. Chartier was arrested.
Chartier was indicted on Count I of possession of pseudoephedrine knowing or having reasonable cause to believe that it would be used to manufacture methamphetamine and Count II of attempted manufacture of methamphetamine. At trial in federal district court, after moving to suppress evidence from the traffic stop, Chartier entered a conditional plea of guilty to Count I, preserving his right to withdraw the plea if the court suppressed the evidence and preserving his right to appeal from any denial of his suppression motion. The district court accepted Chartier's guilty plea, denied in part his motion to suppress, dismissed Count II, and sentenced him to 113 months' imprisonment. On appeal, Chartier contended that the district court erred in denying in part his motion to suppress evidence.
Did the district court err in denying in part Chartier's motion to suppress evidence?
The appellate court held that the traffic stop did not violate Chartier's Fourth Amendment rights. Given the circumstances, Naaktgeboren had an articulable and objectively reasonable suspicion that a motorist without a valid license was driving the vehicle, and his decision to initiate a traffic stop did not violate the Fourth Amendment. Moreover, the court held that the duration and scope of the traffic stop were reasonable because the facts of the case gave Naaktgeboren a particularized and objective basis to extend the scope and duration of the traffic stop and to walk Reso around the vehicle.
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