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Justia Opinion Summary
Appellant entered a conditional plea agreement and pled guilty to possession with intent to distribute 500 grams or more of a mixture or substance containing a detectable amount of cocaine. As allowed by his conditional guilty plea, Appellant challenged the district court's denial of his motion to suppress. The Eighth Circuit Court of Appeals affirmed, holding (1) there was probable cause to stop Appellant; (2) there was reasonable suspicion to detain Appellant in order to search his vehicle; (3) the law enforcement officer's questions did not amount to an unreasonable search; (4) the time spent waiting for a drug detection dog was not unreasonable; and (5) the search of Appellant's vehicle after he was placed in a custodial arrest did not exceed the proper scope of investigation.
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Court Description: Criminal case - Criminal law. Defendant's traffic violation provided probable cause to stop his vehicle; defendant's nervous behavior, conflicting answers and misrepresented criminal history gave the officer reasonable suspicion that defendant was engaged in illegal activity; questioning did not impermissibly extend the traffic stop or violate defendant's Fourth Amendment rights; time spent waiting for a drug detection dog was not unreasonable as the wait was unavoidable and was not the result of a lack of due diligence by the arresting officer; after the drug dog alerted, the officers were permitted to search the trunk of defendant's vehicle under the automobile exception to the warrant requirement, and the scope of the search did not violate the Fourth Amendment.
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