United States v. Cecilio Broca-Martinez, 855 F.3d 675

In Dec. 2015 HSI surveilled a residence and reported a gray Nissan Altima to Laredo PD as a vehicle of interest. Officer Leal later saw an Altima matching the description, ran the plate in his in-vehicle NCIC/TCIC system, and received an “unconfirmed” insurance status.
Based on his experience with the database and Texas law requiring financial responsibility, Leal concluded the vehicle was likely uninsured and stopped it for that traffic offense.
After the stop, Broca‑Martinez admitted he was in the U.S. illegally; Leal cited him for lack of insurance and driving without a license. HSI obtained consent to search his residence and found 14 undocumented immigrants.
Broca‑Martinez was indicted for conspiring to harbor and transport undocumented aliens (8 U.S.C. § 1324), moved to suppress evidence from the stop arguing the initial stop lacked reasonable suspicion, and preserved the issue on conditional guilty plea.
The district court denied the suppression motion; the Fifth Circuit reviewed de novo whether the stop was supported by reasonable suspicion and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable suspicion to stop vehicle based on database “unconfirmed” insurance status	Broca‑Martinez: “Unconfirmed” is ambiguous and insufficient; officer needed corroboration or proof of database reliability	Government/Leal: Officer’s experience with the NCIC/TCIC and testimony about the system’s operation made the “unconfirmed” response a particularized, articulable fact supporting reasonable suspicion	Court: Reasonable suspicion existed—officer’s familiarity and record about the system’s reliability made “unconfirmed” sufficiently particularized to justify the stop

United States v. Lopez-Moreno, 420 F.3d 420 (5th Cir. 2005) (review standard for suppression findings)
United States v. Castillo, 804 F.3d 361 (5th Cir. 2015) (reasonable suspicion need not equal probable cause)
United States v. Cortez, 449 U.S. 411 (U.S. 1981) (reasonable-suspicion standard: particularized and articulable facts)
United States v. Cortez-Galaviz, 495 F.3d 1203 (10th Cir. 2007) (database return indicating no insurance can justify a stop)
United States v. Esquivel-Rios, 725 F.3d 1231 (10th Cir. 2013) (stop unsupported where record showed database unreliability)
United States v. Miranda-Sotolongo, 827 F.3d 663 (7th Cir. 2016) (reasonable suspicion does not require ruling out innocent explanations)
United States v. Sandridge, 385 F.3d 1032 (6th Cir. 2004) (database indications can support a stop)
United States v. Stephens, 350 F.3d 778 (8th Cir. 2003) (absence of registration on database can justify stop)