United States v. Esquivel-Martinez, 23-40660

Omar Esquivel-Martinez was stopped and arrested by U.S. Border Patrol in southern Texas, near the U.S.-Mexico border.
He conditionally pleaded guilty to conspiracy to transport an undocumented alien, reserving his right to appeal the denial of his motion to suppress evidence obtained from a roving patrol stop.
The stop, which led to his arrest, occurred within 13 miles of the border, in an area known for human and drug smuggling.
The Border Patrol agent involved relied on a reliable tip about recent smuggling, observed Esquivel's vehicle driving in tandem with a suspected scout car, and noted other suspicious behaviors (erratic driving, monitoring the agent, near traffic accidents).
Esquivel argued the stop was not supported by reasonable suspicion and, thus, any evidence obtained should be suppressed.
The district court denied the suppression motion, and Esquivel appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the roving patrol stop was supported by reasonable suspicion	Government asserts that under the totality of the circumstances, there was ample reasonable suspicion for the stop	Esquivel contends that agents lacked reasonable suspicion and the stop violated the Fourth Amendment	The Court found reasonable suspicion existed and upheld the denial of the suppression motion

United States v. Brignoni-Ponce, 422 U.S. 873 (U.S. 1975) (sets framework for factors establishing reasonable suspicion in border area stops)
United States v. Villalobos, 161 F.3d 285 (5th Cir. 1998) (discusses proximity to border as a factor in reasonable suspicion)
United States v. Ceniceros, 204 F.3d 581 (5th Cir. 2000) (explains use of be-on-the-lookout advisories or tips in reasonable suspicion analysis)
United States v. Ibarra, 493 F.3d 526 (5th Cir. 2007) (describes collective knowledge doctrine for law enforcement)
United States v. Wright, 74 F.4th 722 (5th Cir. 2023) (applies collective knowledge doctrine to reasonable suspicion determination)