United States v. Cole
6:24-cr-00080
| E.D. Okla. | Jun 5, 2025Background
- Defendants Jason Dale Cole and Crystal Faye Chesser were indicted on multiple drug and firearm charges after a traffic stop, vehicle search, and subsequent residential search.
- Oklahoma Highway Patrol Trooper Mulkey initiated a traffic stop based on speeding and knowledge of Cole’s prior felony and drug-related activity; Cole fled, leading to a pursuit and arrest.
- The initial search of Cole’s vehicle yielded firearms and methamphetamine, which were then used to obtain a search warrant for Cole’s residence.
- A search of the residence recovered substantial additional firearms, drugs, and cash.
- Defendants moved to suppress all evidence from the vehicle and home, challenging the legality of the traffic stop, vehicle search, search warrant, and Trooper Mulkey’s credibility.
- The Magistrate Judge conducted a suppression hearing and recommended denial of both motions to suppress.
Issues
| Issue | Government's Argument | Defendants' Argument | Held |
|---|---|---|---|
| Legality of Traffic Stop and Arrest | Stop justified by speeding; arrest by flight and felony status | Stop itself not challenged | Stop and arrest were lawful |
| Warrantless Vehicle Search | Search justified by plain view, probable cause; alternatively, inevitable discovery | Search not incident to arrest; plain view not credible; no inventory search | Search valid under automobile & plain view doctrines, and inevitable discovery |
| Validity of Search Warrant | Warrant supported by probable cause, corroborated by traffic stop evidence; errors not material | Warrant based on stale and unreliable information, omissions, and informant incentive | Warrant valid; corroboration sufficient; good faith exception applies |
| Suppression of Defendant Statements | No taint as searches were valid | Should be suppressed as fruit of poisonous tree | No suppression; no illegal search or taint |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (traffic stop valid if probable cause for traffic violation)
- Arizona v. Gant, 555 U.S. 332 (limiting vehicle search incident to arrest)
- United States v. Ross, 456 U.S. 798 (automobile exception and scope of warrantless vehicle search)
- California v. Acevedo, 500 U.S. 565 (police may search containers in vehicles with probable cause)
- Chambers v. Maroney, 399 U.S. 42 (probable cause suffices for warrantless vehicle search)
- Maryland v. Dyson, 527 U.S. 465 (reiterating automobile exception standard)
- United States v. Leon, 468 U.S. 897 (good faith exception to exclusionary rule on defective warrants)
- Chimel v. California, 395 U.S. 752 (scope of search incident to arrest)
- Coolidge v. New Hampshire, 403 U.S. 443 (plain view doctrine)
- Delaware v. Prouse, 440 U.S. 648 (constitutional check on suspicionless vehicle stops)