United States v. Andre Reaves
2015 U.S. App. LEXIS 13745
| 7th Cir. | 2015Background
- Reaves suspected of large-scale heroin distribution in Peoria; informant linked his white Chrysler Pacifica to drug trafficking and trips to Detroit.
- Police confirmed ownership and, after a lineup identification, conducted four controlled buys with the informant.
- Following the buys, officers obtained a warranted GPS tracker on the Pacifica to monitor suspected trafficking activity.
- GPS data showed the Pacifica heading to Detroit and returning via I-74, leading to a traffic stop in Peoria for drifting between lanes.
- Seekins (driving) and Reaves consented to a vehicle search; Seekins was arrested for driving on a suspended license, and the car was towed for impound and inventory procedures.
- During the inventory/search, officers found approximately 170 grams of heroin and $6,000; Reaves was arrested and later charged with possession with intent to distribute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause to stop for traffic violation | Reaves contends no probable cause existed to stop the Pacifica. | Leach had an objectively reasonable basis to believe a traffic violation occurred. | Probable cause existed to stop for a traffic violation. |
| Search based on automobile exception | Search lacked a warrant and probable cause was insufficient for the automobile exception. | Probable cause, aided by informant tips corroborated by GPS, justified a warrantless search under the automobile exception. | Police had probable cause to search the vehicle under the automobile exception; suppression denied. |
Key Cases Cited
- United States v. McDonald, 453 F.3d 958 (7th Cir. 2006) (probable cause and de novo review standards for suppression rulings)
- United States v. Muriel, 418 F.3d 720 (7th Cir. 2005) (objective basis for traffic-stop probable cause)
- United States v. Dowthard, 500 F.3d 567 (7th Cir. 2007) (probable cause for traffic stop; standard applied)
- United States v. Edwards, 769 F.3d 509 (7th Cir. 2014) (automobile exception foundations and exigent circumstances)
- United States v. Washburn, 383 F.3d 638 (7th Cir. 2004) (informant tips corroborated by police observations support probable cause)
- United States v. Taylor, 627 F.3d 674 (7th Cir. 2010) (affirming district court on alternate grounds)