United States v. Bob Woods
2016 U.S. App. LEXIS 12991
8th Cir.2016Background
- On April 9, 2014, Sgt. DeLisle stopped Bob L. Woods’ car after seeing heavily tinted windows and Woods throw paper (litter) from the vehicle; stop began at 12:46 p.m.
- DeLisle observed a fake iPhone that was actually digital scales and detected a faint marijuana odor; DeLisle also had prior information that Woods was a drug trafficker who used hidden compartments in his vehicle.
- Woods consented to a vehicle search; DeLisle requested a drug-detecting canine and issued citations for littering and no proof of insurance, taking roughly 15–20 minutes to complete those matters.
- The canine arrived about 40 minutes after the stop began (1:24 p.m.) and alerted to narcotics; officers then impounded and searched the car and found marijuana, methamphetamine, cocaine, and a firearm in a hidden compartment.
- Woods was interviewed at the station after Miranda warnings (refused to sign part of the form but spoke and admitted ownership of the drugs/firearm); he was interviewed again by federal officers two days later after being read Miranda again and made similar admissions.
- Woods moved to suppress the physical evidence and statements arguing (1) unlawful extension of the traffic stop to wait for the canine and (2) invalid Miranda waiver; the district court denied the motion and the jury convicted Woods on drug and firearm counts; sentence = 180 months.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers unlawfully extended the traffic stop to wait for a drug dog, violating the Fourth Amendment | Woods: After citations were issued, officers lacked reasonable suspicion to detain him further to await a canine | Government: Totality of circumstances (marijuana odor, scales disguised as phone, prior intel about hidden compartments, conflicting travel destinations) gave reasonable suspicion to expand the stop | Court: Affirmed — reasonable suspicion existed; ~20-minute wait for canine was lawful |
| Whether statements were inadmissible because Woods refused to sign a Miranda waiver | Woods: Refusal to sign the written form meant he did not waive Miranda rights, so subsequent questioning was invalid | Government: Miranda warnings were given; Woods orally acknowledged understanding and voluntarily answered questions; refusal to sign form is not dispositive | Court: Affirmed — waiver can be oral; Woods knowingly and voluntarily waived and answered questions |
Key Cases Cited
- Rodriguez v. United States, 575 U.S. 348 (2015) (officers may not extend completed traffic stop to conduct dog sniff without reasonable suspicion)
- Terry v. Ohio, 392 U.S. 1 (1968) (reasonable suspicion requires specific, articulable facts)
- Illinois v. Gates, 462 U.S. 213 (1983) (reasonable-suspicion/probable-cause analysis based on totality of circumstances)
- United States v. Maltais, 403 F.3d 550 (8th Cir. 2005) (detention to obtain canine reasonable where officer knew vehicle had hidden compartments and suspect linked to drug activity)
- United States v. Bloomfield, 40 F.3d 910 (8th Cir. 1994) (one-hour detention to wait for canine lawful when reasonable suspicion of drug activity exists)
- United States v. White, 42 F.3d 457 (8th Cir. 1994) (lengthy wait for canine can be reasonable under appropriate circumstances)
- United States v. House, 939 F.2d 659 (8th Cir. 1991) (waiver of Miranda may be inferred from suspect’s responses after being advised of rights)
- Simmons v. Bowersox, 235 F.3d 1124 (8th Cir. 2001) (invocation of right to remain silent must be unequivocal)
- Martin v. United States, 691 F.2d 1235 (8th Cir. 1982) (refusal to sign waiver form does not necessarily render subsequent statements inadmissible)