United States v. $45,000.00 in United States Currency, 749 F.3d 709

Martins stopped on I-80 near Omaha for an obstructed rear license plate under Neb. Rev. Stat. § 60-399(2).
Deputy Wintle testified post-stop he could read the plate’s issuing state only from within 100 feet; suppression hearing differed from trial testimony about readability.
Camera atop the plate partially obscured the state name ‘Utah,’ which Deputy Wintle later read at close range.
After stopping Martins, Wintle detained him in the squad car and deployed a drug-dog; the dog indicated a hidden currency.
A full vehicle search yielded $45,000 in cash but no drugs; the money was forfeited after a civil in rem proceeding; Martins moved to suppress the stop and evidence.
District court adopted the suppression-hearing findings; on appeal the court held the stop violated the Fourth Amendment and reversed, not addressing the canine sniff or the currency-forfeiture issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop was supported by probable cause under § 60-399(2).	Martins (plaintiff) contends Wintle lacked probable cause because plate was readable within 100 feet.	Martins (defendant)? actually Wintle’s reading supports a stop; the government argues readable plate constitutes violation.	Stop improper; no probable cause.
Whether the canine sniff and subsequent detention were lawful.	Martins argues detention beyond completion of the plate issue violated the Fourth Amendment.	Government contends evidence supports detention after initial stop.	Not reached; issue reserved because stop unconstitutional.
Whether the currency forfeiture met the substantial-connection requirement.	Martins challenges the connection between money and drug-trafficking.	Government asserts substantial connection proved by preponderance.	Not reached; do not decide.

United States v. Vanover, 630 F.3d 1108 (8th Cir. 2011) (standard for appellate review of suppression rulings)
United States v. $7,850.00 in U.S. Currency, 7 F.3d 1355 (8th Cir. 1993) (exclusionary rule in forfeiture context)
Harris v. United States, 617 F.3d 977 (8th Cir. 2010) (readability/readable vs. plainly visible license plates)
United States v. Sanchez, 572 F.3d 475 (8th Cir. 2009) (pre-stop readability considerations in license-plate cases)
United States v. Smart, 393 F.3d 767 (8th Cir. 2005) (readability deemed not controlling for stop validity after stop)
Hollins v. United States, 685 F.3d 703 (8th Cir. 2012) (lack of plates and initial stop context)
State v. Richardson, 763 N.W.2d 420 (Neb. App. 2008) (readability as test under § 60-399(2))
State v. Reiter, 524 N.W.2d 575 (Neb. App. 1994) (visibility standard under prior statute)
People v. White, 93 Cal.App.4th 1022 (Cal. App. 2001) (license plate must be entirely readable; unobstructed view)
Parks v. State, 247 P.3d 857 (Wyo. 2011) (license plate plainly visible/readable interpretation)