944 F.3d 740
8th Cir.2019Background
- Early morning June 11, 2017: Officer Bennett responded to a traffic accident involving Delandus McGhee; McGhee was cited for unsafe driving and released.
- About 25 minutes later Bennett saw McGhee driving in the same area, ran a records check, and learned of an outstanding arrest warrant and a suspended license.
- Bennett located McGhee asleep in a parked car, woke him, ordered him out, and secured his arms; McGhee reached toward the floormat as he exited.
- Bennett grabbed and handcuffed McGhee, who said he had been reaching for a shoe; Bennett retrieved the shoe and observed the floormat had a conspicuously raised center.
- Bennett lifted the floormat and discovered a handgun; McGhee was charged with being a felon in possession of a firearm.
- McGhee moved to suppress the gun as the product of a warrantless search; the district court denied suppression without an evidentiary hearing, and McGhee pleaded guilty conditionally to preserve appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless search of the car satisfied the automobile-exception probable-cause standard | McGhee: search was warrantless and lacked probable cause to search the vehicle | Gov./Bennett: totality of circumstances (recent evasive conduct, reaching toward floormat, raised floormat, warrant) supplied probable cause | Court: Affirmed — probable cause existed; automobile exception applies |
| Whether the district court erred by denying a suppression hearing | McGhee: facts disputed and required an evidentiary hearing | Gov.: parties agreed to material facts; district court properly decided without hearing | Court: No abuse of discretion; hearing unnecessary given agreed facts |
Key Cases Cited
- Riley v. California, 573 U.S. 373 (warrantless-search exceptions and privacy expectations in vehicles)
- United States v. Shackleford, 830 F.3d 751 (standard of review and probable-cause framework for vehicle searches)
- United States v. Grooms, 602 F.3d 939 (automobile exception and mobility/lower privacy expectations)
- United States v. Jones, 535 F.3d 886 (evasive behavior supports probable cause)
- United States v. Ameling, 328 F.3d 443 (false statements and inconsistent stories can support probable cause)
- United States v. Murillo-Salgado, 854 F.3d 407 (probable cause defined as facts warranting a reasonable belief contraband will be found)
- United States v. Donnelly, 475 F.3d 946 (probable cause threshold explained—not the same as proof beyond a reasonable doubt)
- United States v. Hager, 710 F.3d 830 (use common-sense, totality-of-circumstances approach to probable cause)
- United States v. Farnell, 701 F.3d 256 (standard for affirming denial of suppression)
- United States v. Stevenson, 727 F.3d 826 (when an evidentiary hearing is required for suppression motions)