United States v. Edward Mincey
699 F. App'x 895
11th Cir.2017Background
- Edward Mincey was stopped in a rental vehicle; he was later convicted of possession with intent to distribute cocaine and marijuana and appealed the denial of his motion to suppress.
- Mincey did not contest the validity of the initial traffic stop; he challenged only the length of the detention and the admissibility of evidence discovered during the extended stop.
- During the stop Mincey (1) briefly moved his car after pulling over, (2) initially refused to exit when ordered, (3) made nervous and evasive responses (visible pulsating carotid artery), and (4) gave inconsistent or suspicious answers about destination, rental terms, and cash payment amount versus his unemployed status.
- Deputy Bruce, experienced in narcotics investigations, developed additional suspicion from these facts and continued the detention to investigate further, leading to a canine sniff/additional investigation that uncovered contraband.
- The district court denied suppression; the Eleventh Circuit reviewed the denial for clear error on facts and de novo on law and affirmed, holding the continued detention was supported by reasonable suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the post-stop detention was unlawfully prolonged | Mincey: continued detention exceeded purpose of stop and required suppression of evidence | Government: officer had articulable reasonable suspicion based on behavior, inconsistent answers, rental/cash anomalies, and officer narcotics experience | Court: affirmed — totality of circumstances gave reasonable suspicion to prolong the stop |
Key Cases Cited
- United States v. Perkins, 348 F.3d 965 (11th Cir. 2003) (standard of review for suppression ruling; reasonable-suspicion principles)
- United States v. Purcell, 236 F.3d 1274 (11th Cir. 2001) (traffic stop is a Fourth Amendment seizure)
- United States v. Simmons, 172 F.3d 775 (11th Cir. 1999) (probable cause for traffic violation justifies stop)
- United States v. Pruitt, 174 F.3d 1215 (11th Cir. 1999) (limits on prolonging traffic stops; need articulable suspicion)
- United States v. Simms, 385 F.3d 1347 (11th Cir. 2004) (legitimate investigative purpose ends after citation/warnings and record checks clear)
- United States v. Tapia, 912 F.2d 1367 (11th Cir. 1990) (articulable suspicion must be based on specific facts and rational inferences)
- Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during unreasonably prolonged stop can violate Fourth Amendment)
- United States v. Arvizu, 534 U.S. 266 (2002) (totality-of-circumstances test for reasonable suspicion)
- United States v. Bautista-Silva, 567 F.3d 1266 (11th Cir. 2009) (innocent explanations for individual facts do not preclude reasonable suspicion)