915 F. Supp. 2d 690
W.D. Pa.2012Background
- Indictment filed March 12, 2008 charging possession with intent to distribute ecstasy, a Schedule I controlled substance, in the Western District of Pennsylvania.
- Payton (1) and Gooch (2) moved to suppress evidence obtained from the May 25, 2007 traffic stop; government responses followed; multiple supplementation motions were granted.
- Corporal Robert F. Johnson of the Pennsylvania State Police stopped a dark Buick on the turnpike near the Allegheny Tunnel for observed window tint and a partially inoperable rear brake light; the stop occurred at approximately 3:30 a.m.
- During the stop, Payton and Gooch were present; Payton reported pregnancy-related cramps, and Johnson discussed travel from New Jersey; Johnson eventually searched Payton’s book bag after a brief consensual phase.
- A white powdery substance (later identified as ecstasy) was found behind a trunk liner after Johnson removed the trunk liner; Payton and Gooch were arrested; Miranda warnings were given with disputed adequacy, leading to suppression findings and a supplemental hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of the traffic stop based on window tint | Payton | Gooch | Stop upheld under reasonable suspicion; tint observed justified stop |
| Constitutionality of the window tint statute (75 Pa. Cons.Stat. § 4524(e)) | Payton | Gooch | Good-faith exception applies; statute not constitutionally foreclosed for purposes of the stop |
| Whether the post-stop encounter was a seizure or consensual | Payton and Gooch | Payton and Gooch | Second encounter deemed consensual; Fourth Amendment not implicated during that phase |
| Validity and scope of Payton's consent to search | Payton | Gooch | Consent valid but limited to Payton's book bag; search of trunk behind liner not within scope; probable cause supported automobile-exception search behind liner |
| Adequacy of on-scene Miranda warnings and admissibility of statements | Payton | Payton | On-scene warnings inadequate; statements obtained before second warning suppressed; supplemental hearing ordered for second set of statements |
Key Cases Cited
- Weeks v. United States, 232 U.S. 383 (U.S. 1914) (exclusionary rule; fruit of the poisonous tree)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (fruit of the poisonous tree; exclusionary rule)
- Schneckloth v. Bustamonte, 412 U.S. 218 (U.S. 1973) (consent to search; voluntariness test)
- Illinois v. Krull, 480 U.S. 340 (U.S. 1987) (good-faith reliance on statute; exclusionary rule exception)
- United States v. Hall, 270 F. App’x 123 (3d Cir. 2008) (window tint reasonable suspicion; stop valid)
- United States v. Brendlin, 551 U.S. 249 (U.S. 2007) (seizure standard for traffic stops; passenger rights)
- Jimeno v. United States, 500 U.S. 248 (U.S. 1991) (scope of consent to search; object-based)
- United States v. Tarburton, 610 F. Supp. 2d 268 (D. Del. 2009) (implied consent limitations; scope of search)
- Concepcion-Ledesma v. United States, 447 F.3d 1307 (10th Cir. 2006) (hidden compartments; probable cause to search)
- Street v. United States, 472 F.3d 1298 (11th Cir. 2006) (Seibert-Elstad framework for warned statements)