United States v. Eric Sudduth
678 F. App'x 564
9th Cir.2017Background
- Police observed Sudduth commit a traffic violation; Detective Gott instructed Officer Boeckman to stop Sudduth’s van.
- At the stop officers learned the license plate was suspended.
- Detective Cragg ordered Sudduth out of the vehicle and, from a lawful position, saw a machete and a pistol in plain view in the passenger compartment.
- A police canine later alerted near the driver’s door; during the encounter Sudduth—after receiving and acknowledging Miranda warnings—admitted he was a felon in possession of a firearm.
- Sudduth pleaded guilty to being a felon in possession (18 U.S.C. § 922(g)(1)) but reserved the right to appeal the denial of his suppression motion; the Ninth Circuit affirmed the denial.
Issues
| Issue | Plaintiff's Argument (Sudduth) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Validity of the stop under collective-knowledge doctrine | Stop invalid because Officer Boeckman lacked personal reasonable suspicion | Detective Gott had reasonable suspicion and communicated an order to stop; collective knowledge applies | Stop justified under collective-knowledge doctrine (Ramirez/Hensley) |
| Whether the stop was unreasonably prolonged to wait for canine/sniff | Officers unlawfully prolonged the stop to await the canine’s arrival | Officers were addressing evolving safety concerns (suspended plate, visible weapons, aggressive behavior); stop not completed | No unreasonable prolongation; actions justified by safety concerns (Rodriguez, Long) |
| Justification for vehicle sweep/search of passenger compartment | Sweep/search exceeded scope; evidence tainted | Cragg lawfully saw pistol in plain view and could conduct protective sweep for officer safety | Protective sweep/search of passenger compartment justified by plain-view firearm (Long) |
| Admissibility of Sudduth’s statements | Statements involuntary/should be suppressed | Cragg read Miranda warnings; Sudduth acknowledged them; statements therefore admissible | Statements admissible under Fifth Amendment (Berghuis) |
Key Cases Cited
- United States v. Ramirez, 473 F.3d 1026 (9th Cir. 2007) (collective-knowledge doctrine supports stops when one officer with reasonable suspicion directs another to act)
- Hensley v. Mayor & City Council of Baltimore, 469 U.S. 221 (1985) (police reliance on information from other officers can justify stops)
- United States v. Williams, 419 F.3d 1029 (9th Cir. 2005) (officer may order occupant out of vehicle for officer safety)
- Rodriguez v. United States, 575 U.S. 348 (2015) (officers may not unduly prolong a traffic stop beyond mission absent reasonable suspicion)
- Michigan v. Long, 463 U.S. 1032 (1983) (protective sweeps of vehicle passenger compartment justified by reasonable belief of danger)
- United States v. Lozano, 623 F.3d 1055 (9th Cir. 2010) (canine alerts and motel observations relevant to vehicle-search analysis)
- Berghuis v. Thompkins, 560 U.S. 370 (2010) (suspect’s acknowledgment of Miranda rights and subsequent statements can be admissible)