United States v. Alberto Anguiano
2015 U.S. App. LEXIS 13473
8th Cir.2015Background
- Anguiano was a passenger in a 2009 Nissan Rogue pulled over for speeding and very dark-tinted windows on I-80 in Iowa.
- Driver Gomez provided license, registration, and insurance; Anguiano provided a Nevada ID and varied answers about ownership and purpose.
- Taylor observed a shiny dash/center console vs. a messy interior; both Gomez and Anguiano appeared extremely nervous.
- Dispatch later reported an outstanding warrant for Anguiano and that he was armed and dangerous, prompting back-up before arrest.
- Taylor temporarily questioned Anguiano and then arrested him; Gomez eventually gave consent to search the vehicle.
- Search revealed contraband and stolen items, including methamphetamine in a center-console panel, a rifle bag with a stolen rifle, and other evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was unreasonably prolonged. | Anguiano argues the stop extended beyond the necessary duration. | Gomez argues stop rationale remained ongoing; reasonable suspicion supported extension. | Stop extended by reasonable suspicion; no error. |
| Whether the vehicle search exceeded the scope of Gomez's consent. | Anguiano contends center console search went beyond consent. | Gomez's consent encompassed search of the vehicle contents. | Anguiano lacked standing to challenge the search; issue not resolved on that basis. |
| Whether Anguiano had standing to challenge the vehicle search as a mere passenger. | Anguiano asserts he had reasonable privacy expectation due to control of the trip. | Gomez argues passenger lacks privacy interest; no standing shown. | Anguiano failed to demonstrate a sufficient connection to the vehicle to establish standing. |
Key Cases Cited
- Barragan v. United States, 379 F.3d 524 (8th Cir. 2004) (routine traffic-stop tasks may extend the stop)
- Linkous v. United States, 285 F.3d 716 (8th Cir. 2002) (can question occupants about destination during stop)
- Olivera-Mendez v. United States, 484 F.3d 505 (8th Cir. 2007) (no per se time limit; extensions may be justified)
- Quintero-Felix v. United States, 714 F.3d 563 (8th Cir. 2013) (reasonable suspicion can justified stop extension)
- Woods v. United States, 747 F.3d 552 (8th Cir. 2014) (totality of circumstances; reasonable suspicion supports extension)
- Gomez v. United States, 16 F.3d 254 (8th Cir. 1994) (standing to challenge search requires close connection to searched property)
- Rakas v. Illinois, 439 U.S. 128 (U.S. 1978) (Fourth Amendment rights are personal)
- Muhammad v. United States, 58 F.3d 353 (8th Cir. 1995) (standing and privacy expectations in searched items)
- Symonevich v. United States, 688 F.3d 12 (1st Cir. 2012) (trip duration alone does not elevate privacy expectation)
- Jefferson v. United States, 925 F.2d 1242 (10th Cir. 1991) (passenger lacks standing even on long trips)
- Luginbyhl v. United States, 321 F. App’x 780 (10th Cir. 2009) (consent-based stop extension considerations)