United States v. Herald Alexander, 528 F. App'x 515

Officers observed two hand-to-hand drug transactions at a gas station involving Alexander and two unidentified individuals, with Alexander then not purchasing gas.
Alexander drove away; officers noted his license-plate light was not working, creating probable cause for a civil traffic violation and justifying a stop.
A drug-detection dog was requested and arrived ~18 minutes after the stop; the dog alerted on the driver-side door, prompting a search.
During the search, crack cocaine in foil was found in the car, and a loaded nine-millimeter handgun was discovered in the trunk along with a digital scale.
Alexander moved to suppress the evidence; the district court denied the motion; new counsel was appointed and the suppression hearing was reopened, with testimony from his mother about the license-plate light.
Alexander pled guilty to felon in possession of a firearm, waiving certain appellate rights; the district court determined a guideline range of 70–87 months and sentenced him to 70 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the stop supported by probable cause or reasonable suspicion?	Alexander contends no probable cause or reasonable suspicion.	Alexander's position is that the stop was unlawful absent such grounds.	Stop supported by probable cause/reasonable suspicion; affirmed.
Was the duration of the traffic stop reasonable?	Alexander argues the stop was unduly lengthy.	Stop duration fell within permissible limits given reasonable suspicion and ensuing actions.	Duration reasonable; affirmed.
Did the district court abuse its discretion in limiting the scope of the reopened suppression hearing?	Alexander contends new counsel should re-cross-examine officers about drug observations.	Court properly limited scope to license-plate light issue; no abuse.	No abuse; affirmed.
Is the sentence within the plea waiver and guideline range?	Alexander argues sentence should be outside or differently interpreted despite waiver.	Waiver covers up to maximum advisory range; sentence within range and waiver valid.	Sentence affirmed; waiver valid; within range.

United States v. Jackson, 470 F.3d 299 (6th Cir. 2006) (probable cause and reasonable suspicion standards; traffic stops)
United States v. Blair, 524 F.3d 740 (6th Cir. 2008) (reasonable suspicion framework for traffic stops)
United States v. Luqman, 522 F.3d 613 (6th Cir. 2008) (deference to officers’ inferences in reasonable suspicion analysis)
United States v. Jones, 673 F.3d 497 (6th Cir. 2012) (hand-to-hand drug transactions as probative of suspicion)
Florida v. Royer, 460 U.S. 491 (1983) (limits on investigative detentions and intrusion during stops)
United States v. Woods, 544 F.2d 242 (6th Cir. 1976) (mutual imputation of knowledge among officers on scene)