People of Michigan v. Eulalio Ramos Jr
329057
| Mich. Ct. App. | Dec 15, 2016Background
- Trooper Gillespie stopped Ramos after observing multiple lane crossings on May 17, 2014; video corroborated the swerving.
- During the stop Gillespie asked for ID, registration, and the trip purpose; Ramos gave inconsistent answers about who he was visiting.
- A small child in the back seat was not restrained in a car seat; Gillespie briefly evaluated Ramos’s ability to drive at the rear of the vehicle and returned Ramos’s documents with a verbal warning.
- After Gillespie told Ramos he would not issue a ticket, he asked if Ramos would answer additional questions; Ramos consented and then consented to a vehicle search.
- The search of the trunk revealed seven large packages of marijuana; Ramos was arrested and charged with possession with intent to deliver 45+ kilograms.
- Ramos moved to suppress the statements and evidence, arguing (1) the initial stop lacked reasonable suspicion and (2) any post-warning detention/search violated Rodriguez; the trial court denied suppression and Ramos appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the initial stop justified at its inception? | Police: observed lane crossings; reasonable suspicion of impaired or unsafe driving. | Ramos: reasons for stop were trivial; no articulable suspicion of crime. | Stop was supported by articulable, reasonable suspicion based on observed swerving. |
| Was Ramos still "seized" after documents were returned? | Police: encounter ended when documents returned and warning given; Ramos was free to leave. | Ramos: continued detention persisted; officer prolonged stop without basis (citing Rodriguez). | Court held a reasonable person would have felt free to leave; not a seizure after documents returned. |
| Did Rodriguez bar further questioning/search after completion of the stop? | Police: Rodriguez inapplicable because Ramos consented to additional questions and the search. | Ramos: post-warning questioning/search unlawfully prolonged stop per Rodriguez. | Ramos’s consent made Rodriguez inapposite; consent validated the further questioning and search. |
| Was Ramos’s consent to search voluntary? | Police: consent was voluntary; no coercion or threats; interaction was congenial. | Ramos: consent was not voluntary given the traffic stop context and timing. | Consent was voluntary under totality of circumstances; search exception applied. |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes stop-and-frisk/reasonable suspicion framework)
- Rodriguez v. United States, 575 U.S. 348 (2015) (prolonging a traffic stop beyond mission requires independent reasonable suspicion)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent to search must be voluntary under totality of circumstances)
- Delaware v. Prouse, 440 U.S. 648 (1979) (stops and seizures of motorists must be justified at inception)
- Jenkins v. Michigan, 472 Mich. 26 (2005) (reasonable-person test for seizure under the Fourth Amendment)
- People v. Williams, 472 Mich. 308 (2005) (application of Terry framework in Michigan traffic-stop context)
- People v. Dillon, 296 Mich. App. 506 (2012) (officer may stop vehicle on articulable, reasonable suspicion)
- People v. Davis, 241 Mich. App. 697 (2000) (trial court credibility findings on stops are given deference)
- Immigration & Naturalization Serv. v. Delgado, 466 U.S. 210 (1984) (consensual responses to police requests often remain voluntary)