United States v. Hyler-Williams
788 F.Supp.3d 1176
D.N.M.2025Background
- On August 1, 2023, Bureau of Indian Affairs (BIA) Officer Jackson stopped a gray Jeep Wagoneer on Interstate 40, Laguna Pueblo, New Mexico, with Patric Hyler-Williams as driver and Leo Berry as passenger.
- Officer Jackson claimed to have stopped the vehicle for speeding, following too closely, and issues related to vehicle registration, though the legitimacy of these reasons was disputed due to inconsistent and unreliable recordkeeping.
- After issuing a written warning (ending the original purpose of the stop), Officer Jackson asked further questions, claimed to smell marijuana, and then searched the vehicle without consent and without obtaining a warrant.
- Officer Jackson discovered significant quantities of fentanyl and methamphetamine during the search, leading to federal drug charges against Defendants.
- Defendants moved to suppress the evidence, arguing the stop was unconstitutionally prolonged and the search lacked probable cause.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop was justified at its inception | Officer had reasonable suspicion of speeding, following too closely, registration issue | Officer did not have reasonable suspicion—registration issue contrived, speeding unsupported | Did not decide; focused on subsequent illegal extension of stop |
| Whether detention of Defendants was unconstitutionally extended | Officer had reasonable suspicion due to smell of marijuana | Extension beyond issuance of warning was not supported by any new reasonable suspicion | Detention was unconstitutionally extended once warning was issued |
| Whether officer had probable cause to search the vehicle | Odor of burnt/unburnt marijuana gave probable cause | No credible evidence officer actually smelled marijuana or had probable cause | Court did not credit officer’s testimony; no probable cause to search |
| Whether suppression of the seized evidence is required | Evidence lawfully obtained, no illegality | Evidence is ‘fruit of the poisonous tree’ from illegal search/seizure | Evidence suppressed as product of Fourth Amendment violations |
Key Cases Cited
- Wong Sun v. United States, 371 U.S. 471 (exclusionary rule applies to derivative evidence from Fourth Amendment violations)
- Murray v. United States, 487 U.S. 533 (defines scope of 'fruit of the poisonous tree')
- Terry v. Ohio, 392 U.S. 1 (standard for investigative detention/seizure)
- Rodriguez v. United States, 575 U.S. 348 (traffic stop cannot be prolonged without reasonable suspicion)
- Florida v. Royer, 460 U.S. 491 (limits on scope and duration of investigative detention)
- United States v. Pettit, 785 F.3d 1374 (expanded on permissible traffic stop activities)
- United States v. Frazier, 30 F.4th 1165 (explains ‘Rodriguez moment’ and illegal detention)
- United States v. Nielsen, 9 F.3d 1487 (odor of marijuana and its relevance to probable cause)
- United States v. Morin, 949 F.2d 297 (probable cause from odor of marijuana must be credible and corroborated)