United States v. GONZALEZ
5:18-cr-00558
E.D. Pa.Aug 2, 2019Background
- Defendant Miguel Gonzalez Segovia was stopped on I-78 on Nov. 13, 2018; Trooper Stepanski observed speeding (68 mph in a 65 zone) and following too closely and initiated a traffic stop.
- Trooper Stepanski questioned Segovia about travel plans, observed nervousness and multiple suitcases, ran database checks, and called for backup. The initial questioning lasted under five minutes; the total stop before consent was under 20 minutes.
- After backup arrived, Stepanski asked Segovia to exit, asked about contraband, requested consent to search, and administered a Pennsylvania consent-to-search form which Segovia signed (he did not read it entirely).
- Stepanski opened a suitcase and discovered approximately thirty sealed packages; subsequent lab testing recovered ~69 kg cocaine, 14 kg fentanyl, and 3.9 kg acetylfentanyl. Segovia was arrested after the search.
- Segovia moved to suppress evidence arguing (1) no reasonable suspicion for the stop; (2) no reasonable suspicion to extend the stop; (3) Miranda warnings were required; and (4) consent was involuntary/tainted. He also raised a selective-enforcement (racial) claim. The district court denied the motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of initial stop | Stop lacked reasonable suspicion/probable cause for traffic violation | Trooper observed speeding and following-too-closely violations | Stop lawful: officer had reasonable suspicion based on observed traffic violations (speed and following distance) |
| Extension of the stop | Further questioning and waiting for backup exceeded the stop’s mission without reasonable suspicion | Officer developed reasonable suspicion from nervousness, travel inconsistencies, heavy luggage, and drug-corridor location | Extension justified: totality of circumstances gave reasonable suspicion to detain until backup arrived |
| Miranda/custodial interrogation | Statements and consent were product of custodial interrogation; warnings required | Roadside questioning during a traffic stop is non-custodial; no coercive tactics or restraints used | No Miranda required: not custodial interrogation under the circumstances |
| Voluntariness of consent to search | Consent was involuntary/tainted by earlier constitutional violations and language issues | Consent was verbal and written, obtained in noncoercive setting after advisement of right to refuse | Consent was voluntary and valid; search therefore reasonable |
| Selective enforcement (race) | Stop/search motivated by defendant’s race; statistical evidence shows bias | Trooper credibly testified he could not see defendant’s race before stopping; statistics incomplete and not probative | Prima facie selective-enforcement claim not shown: no evidence of discriminatory intent or sufficient statistical proof |
Key Cases Cited
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes standards for investigative stops and seizures)
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial interrogation requires Miranda warnings)
- Whren v. United States, 517 U.S. 806 (1996) (subjective officer intent irrelevant when objective traffic violation exists)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (traffic-stop mission must be completed before extension; additional reasonable suspicion required to prolong stop)
- United States v. Delfin-Colina, 464 F.3d 392 (3d Cir. 2006) (traffic stops analyzed under Terry framework)
- United States v. Green, 897 F.3d 173 (3d Cir. 2018) (identify Rodriguez moment and assess reasonable suspicion at that time)
- Illinois v. Wardlow, 528 U.S. 119 (2000) (nervous, evasive behavior is relevant to reasonable-suspicion analysis)
- Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent-to-search voluntariness assessed under the totality of the circumstances)
- Arizona v. Gant, 556 U.S. 332 (2009) (limits on vehicle searches incident to arrest)