United States v. Erickson Meko Campbell, 912 F.3d 1340

Background

Around 9:00 PM an I-20 deputy observed Erickson Campbell's Nissan cross the fog line and have a rapidly blinking left turn signal; deputy pulled him over and activated dashboard camera.
Deputy inspected lights, decided signal was malfunctioning, and chose to issue a warning for the signal and lane maintenance; asked Campbell to accompany him to the patrol car while writing the warning.
While writing the warning (and after dispatch identified Campbell as an "active felon"), the deputy asked various questions about Campbell's destination, work, criminal history, and whether he had contraband; Campbell denied contraband and then consented to a car search.
Deputies found a 9mm pistol and related items in a hidden trunk compartment; Campbell (a convicted felon) was charged under 18 U.S.C. § 922(g)(1).
Campbell moved to suppress, arguing (1) no reasonable suspicion justified the stop for the blinking signal, and (2) the stop was unlawfully prolonged by unrelated questioning (tainting his consent); District Court denied suppression. Campbell pled guilty conditionally and appealed.

Issues

Issue	Campbell's Argument	Government's Argument	Held
1. Did the rapidly blinking turn signal supply reasonable suspicion for a traffic stop?	Blinking signal still indicated intention to turn; statute does not require blink rate; no violation.	Rapid blinking reasonably suggested a "not in good working condition" violation under O.C.G.A. § 40-8-26.	Yes. Court held the rapid blinking gave reasonable suspicion to stop (signal may indicate bulb/wiring problem).
2. Did officer unlawfully prolong the stop by asking unrelated questions about contraband?	Questions about contraband and other crimes were unrelated and unlawfully lengthened the stop.	Some questions (destination, criminal history, firearm) were related to safety/traffic mission; brief unrelated questions were de minimis or covered by then-controlling precedent.	Yes. Court held the contraband questions (25 seconds) were unrelated, added time, and lacked reasonable suspicion, so they unlawfully prolonged the stop under Rodriguez.
3. If prolonged unlawfully, must evidence be suppressed?	Illegally prolonged detention taints subsequent search; evidence should be suppressed unless consent purged taint or another exception applies.	The officers acted in objectively reasonable reliance on Eleventh Circuit precedent (Griffin); Davis good-faith exception prevents suppression.	No suppression. Because officers relied on binding Eleventh Circuit precedent (Griffin), the Davis good-faith exception applies and evidence is admissible.
4. Was the consent to search valid / purge the taint?	Consent was a product of unlawful detention; therefore invalid.	Government did not rely primarily on consent; invoked good-faith reliance on precedent instead.	Not decided: court did not reach voluntariness/product analysis because good-faith exception resolved admissibility.

Key Cases Cited

Rodriguez v. United States, 575 U.S. 348 (2015) (traffic-stop mission limits: officers may not prolong a stop to conduct unrelated investigations absent reasonable suspicion)
Davis v. United States, 564 U.S. 229 (2011) (exclusionary rule does not apply to evidence obtained in objectively reasonable reliance on binding precedent)
United States v. Griffin, 696 F.3d 1354 (11th Cir. 2012) (pre-Rodriguez Eleventh Circuit standard allowing brief unrelated questioning if overall stop remained reasonable)
Heien v. North Carolina, 574 U.S. 54 (2014) (reasonable mistake of law can supply reasonable suspicion)
Whren v. United States, 517 U.S. 806 (1996) (traffic stops are Fourth Amendment seizures justified by probable cause; subjective officer motive irrelevant)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during stop permissible if it does not prolong the stop)
Arizona v. Johnson, 555 U.S. 323 (2009) (officer may make inquiries unrelated to traffic stop if they do not extend its duration)