United States v. Washington - 455 F.3d 824 (8th Cir. 2006)

Rule:

An appellate court reviews a district court's findings of fact for clear error and its legal conclusions about probable cause and reasonable suspicion de novo. Under the Fourth Amendment, a traffic stop is reasonable if it is supported by either probable cause or an articulable and reasonable suspicion that a traffic violation has occurred. It is well-established that any traffic violation, regardless of its perceived severity, provides an officer with probable cause to stop the driver. Nonetheless, the police must objectively have a reasonable basis for believing that the driver has breached a traffic law. 

Facts:

Timothy Washington entered a conditional guilty plea to being a felon in possession of a firearm in violation of 18 U.S.C. § 922(g), and the district court sentenced him to 21 months' imprisonment followed by 3 years of supervised release. He appealed from the district court's order denying his motion to suppress evidence obtained after police officers stopped the vehicle he was riding in for having a cracked windshield. The government conceded that having a cracked windshield does not violate Nebraska law, and Washington argued that the investigating officer therefore did not have reasonable suspicion or probable cause to stop the vehicle. 

Issue:

Did the district court err in denying Washington’s motion to suppress evidence obtained after police officers stopped the vehicle he was riding in for having a cracked windshield?

Answer:

Yes.

Conclusion:

The appellate court reversed the district court's order and vacated Washington’s plea and sentence because although officers had broad authority to stop vehicles for any traffic violation, regardless of how minor, they had to have a legal justification for the stop that was grounded in the state's law. The officer's understanding of Nebraska law, specifically the vision obstruction statute, Neb. Rev. Stat. § 60-6256, was unreasonable and the government therefore failed to establish that it had probable cause to stop the vehicle. Therefore, the traffic stop was unconstitutional, and the firearm and Washington’s statements to the police should have been suppressed.