People v. Matthew
2011 V.I. LEXIS 55
Superior Court of The Virgin I...2011Background
- Defendants Morton, Gordon A., Gordon P., and Matthews moved to suppress weapons and statements as unconstitutional under the Fourth and Fifth Amendments.
- Officers Wright and Francis stopped a white/beige Toyota Forerunner with five occupants at about 1:41 a.m. near Concordia, Frederiksted, St. Croix, for speeding and failure to stop at a stop sign.
- During the stop, concerns for officer safety arose (outnumbered occupants, night time, juvenile in the vehicle, and potential attempt to open a rear door).
- After exiting the vehicle, Wright illuminated the interior and allegedly observed a handgun in plain view, prompting arrests of all occupants.
- A weapon was found on the juvenile, and a third weapon was discovered in a rear door compartment; occupants were taken to the station, advised of rights, and questioned about firearm licenses.
- Defendants moved to suppress the seized firearms and any derivative evidence, arguing the traffic stop and subsequent arrest violated Virgin Islands law and the Fourth/Fifth Amendments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was constitutionally permissible | Morton argues the stop was invalid. | Gordon contends stop was authorized by observed violations. | The stop was constitutionally permissible under the authorization test. |
| Whether the arrest after the first weapon was discovered was supported by probable cause | Statutory inquiry required before arrest; record shows no pre-arrest license inquiry. | Statutory authority permitted investigation but not performed pre-arrest. | Officers failed to inquire pre-arrest; suppression of evidence derived from unlawful arrest. |
Key Cases Cited
- United States v. Johnson, 63 F.3d 242 (3d Cir. 1995) (authorization test for traffic stops; objective basis required)
- Delaware v. Prouse, 440 U.S. 648 (U.S. 1979) (stop and license check requires articulable suspicion or probable cause)
- Whren v. United States, 517 U.S. 806 (U.S. 1996) (prior decisions on reasonable basis for traffic stops; objective assessment)
- United States v. Montoya de Hernandez, 473 U.S. 531 (U.S. 1985) (reasonableness of searches under totality of circumstances; Terry exception noted)
- Horton v. California, 496 U.S. 128 (U.S. 1990) (exclusion of warrantless searches except under exceptions; reasonable searches)