United States v. Federico Saldana
667 F. App'x 522
5th Cir.2016Background
- Federico Saldana pleaded guilty (conditionally) to possession with intent to distribute ≥5 kg of cocaine and reserved the right to appeal denial of a suppression motion.
- Officers stopped Saldana’s vehicle after observing multiple traffic violations.
- During the stop officers questioned Saldana and observed behavior and circumstances (nervousness, vague trip purpose, prior criminal history, appearance of truck/trailer) that raised suspicion of narcotics trafficking.
- Officers obtained Saldana’s consent—twice—to search the vehicle; no limits on scope were asserted.
- The search produced evidence used against Saldana; he argued the detention was illegal and the search exceeded consent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the initial traffic stop lawful? | (Gov) Stop justified by observed traffic violations | Saldana contests legality of stop | Held lawful: officers had objectively reasonable suspicion (traffic violations) |
| Did officers have reasonable suspicion to continue detention? | (Gov) Post-stop questioning and observations created reasonable suspicion of narcotics activity | Saldana argued continued detention was illegal | Held reasonable: behavior, vague trip purpose, prior history, and vehicle appearance supported continued detention |
| Was consent to search the fruit of an illegal detention? | (Gov) Consent was voluntary and not tainted by unlawful detention | Saldana argued consent was a product of illegal detention | Held consent was not preceded by illegal detention, so argument fails |
| Did the search exceed the scope of consent? | (Gov) Consent was broad and unqualified | Saldana argued the search exceeded his consent | Held no: Saldana gave consent twice without limits; no error shown |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes two‑pronged stop-and-frisk framework)
- United States v. Pack, 612 F.3d 341 (5th Cir.) (standard of review for suppression rulings)
- United States v. Brigham, 382 F.3d 500 (5th Cir.) (test for whether subsequent police action is related to stop)
- United States v. Lopez-Moreno, 420 F.3d 420 (5th Cir.) (traffic violations can justify an investigative stop)
- United States v. Gonzalez, 328 F.3d 755 (5th Cir.) (factors supporting reasonable suspicion during a stop)
- United States v. Estrada, 459 F.3d 627 (5th Cir.) (officer observations may establish reasonable suspicion of narcotics trafficking)
- United States v. Sanchez, 507 F.3d 877 (5th Cir.) (same; evaluating totality of circumstances)
- United States v. Khanalizadeh, 493 F.3d 479 (5th Cir.) (consent not tainted when detention was lawful)
- United States v. Baker, 538 F.3d 324 (5th Cir.) (scope of consent principles)
- United States v. Rich, 992 F.2d 502 (5th Cir.) (consent analysis and limits on search)