United States v. Carlos Gonzales-Gomez, 703 F. App'x 335

Border Patrol stopped a Ford pickup at an inland immigration checkpoint on Highway 4 near Brownsville; five occupants included Gonzales (driver) and co-defendant Esquivel (backseat).
Agents referred the vehicle to secondary inspection because three rear occupants lacked ID and one (Esquivel) appeared nervous; Esquivel matched BOLO alerts for marijuana trafficking.
Ground agents had found ~53 bundles of marijuana (over 500 kg) a quarter-mile from a fenced property; an abandoned septic/tanker truck with a hot motor, registered to Esquivel, was nearby and appeared capable of concealing single bundles.
Two agents (Davidson and Garcia), informed of the surrounding seizure and BOLOs, arrived at the checkpoint, questioned Esquivel and Gonzales, found evasive and inconsistent answers, and detained them for further questioning; both were given Miranda warnings and transported to the station.
Gonzales signed a written Miranda waiver ~3 hours later at the Border Patrol station and was later arrested; Esquivel pleaded guilty and testified against Gonzales. The district court denied Gonzales’s suppression motion; this appeal followed.

Issue	Gonzales’s Argument	Government’s Argument	Held
Whether agents had reasonable suspicion to extend the checkpoint detention to investigate drug trafficking	Agents lacked reasonable suspicion; extension exceeded checkpoint scope	Agents had reasonable suspicion based on (a) large nearby marijuana seizure, (b) abandoned septic truck registered to Esquivel, (c) BOLOs linking Esquivel to trafficking, and (d) evasive/inconsistent answers	Court: Held reasonable suspicion existed and justified extension of the stop
Whether Gonzales’s Miranda waiver at the station was involuntary due to prolonged detention/heat or misleading questioning	Waiver involuntary because prolonged detention in hot conditions and he was not told drugs were the focus	Waiver voluntary: signed waiver, no coercion, cooperative behavior, Miranda warnings given, DEA agent present and investigation for narcotics disclosed	Court: Held waiver voluntary and statements admissible

United States v. Macias, 658 F.3d 509 (5th Cir. 2011) (view suppression hearing facts in light most favorable to prevailing party)
United States v. Machuca-Barrera, 261 F.3d 425 (5th Cir. 2001) (initial lawful immigration stop may support further investigation only if it creates reasonable suspicion)
Goodson v. City of Corpus Christi, 202 F.3d 730 (5th Cir. 2000) (reasonable suspicion standard is less demanding than probable cause)
United States v. Jacquinot, 258 F.3d 423 (5th Cir. 2001) (factors supporting reasonable suspicion in drug interdiction context)
North Carolina v. Butler, 441 U.S. 369 (1979) (signed waiver is strong evidence of voluntariness)
Colorado v. Connelly, 479 U.S. 157 (1986) (police coercion is central to involuntariness analysis)
Soffar v. Cockrell, 300 F.3d 588 (5th Cir. 2002) (deceit by interrogators does not render waiver involuntary unless it deprives suspect of essential knowledge to understand rights)
Moran v. Burbine, 475 U.S. 412 (1986) (discusses effect of police misrepresentations on Miranda waiver)
United States v. Martinez-Fuerte, 428 U.S. 543 (1976) (permissible suspicionless stops at interior immigration checkpoints)