United States v. Adrian Ruiz
2015 U.S. App. LEXIS 7645
| 7th Cir. | 2015Background
- DEA officers surveilled a storefront suspected of drug activity and tied Ruiz to the target investigation; Ruiz entered a mall parking lot and interacted with trap-like compartments in a car; officers observed Ruiz manipulating vehicle controls suggesting trap operation; Ruiz consented to a car search which yielded no drugs; officers then escorted Ruiz to a police station where he opened traps containing heroin after a discussion about a canine unit; Ruiz ultimately pled guilty while preserving the right to appeal the denial of the suppression motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the stop had reasonable suspicion. | Ruiz; not enough facts to justify detaining. | State; totality of circumstances supported suspicion. | Yes, reasonable suspicion existed. |
| Whether the stop ripened into an arrest. | Stop extended beyond purpose; unconstitutional detention. | Investigation reasonably related in scope and duration. | No, detention stayed within permissible limits. |
| Whether Ruiz was custodial before Miranda warnings. | Yes, coercive custody during driveway encounter. | No custody; public setting and voluntary cooperation. | Not custodial prior to Miranda. |
| Whether Ruiz's consent to go to the station and open traps was voluntary. | Consent obtained under duress or coercion implied by circumstances. | Consent voluntary given the totality of circumstances. | Consent voluntary. |
Key Cases Cited
- United States v. Arvizu, 534 U.S. 266 (U.S. 2002) (totality-of-the-circumstances test for reasonable suspicion)
- Terry v. Ohio, 392 U.S. 1 (U.S. 1968) (reasonable suspicion standard for investigatory stops)
- Alabama v. White, 496 U.S. 325 (U.S. 1990) (reasonable suspicion and reliability of information)
- United States v. Royer, 460 U.S. 491 (U.S. 1983) (limit on detention duration; reasonable investigation)
- United States v. Bullock, 632 F.3d 1004 (7th Cir. 2011) (duration and scope of investigative stops; dog sniff context)
- Vega, 72 F.3d 507 (7th Cir. 1995) (reasonable extension for canine sniff within Terry stop)
- United States v. Taylor, 596 F.3d 373 (7th Cir. 2010) (consent to search as critical timing for reasonableness of stop)
- United States v. Muriel, 418 F.3d 720 (7th Cir. 2005) (factors for evaluating voluntariness of consent)