United States v. Jesus Quintero-Felix
2013 U.S. App. LEXIS 8925
8th Cir.2013Background
- Quintero-Felix was convicted of conspiracy to distribute fifty grams or more of methamphetamine and aiding and abetting distribution of methamphetamine.
- Police stopped a blue California-tagged truck for lacking a front plate; the driver was Quintero-Felix and the passenger Zamudio-Hernandez.
- During the stop, Quintero-Felix exhibited unusual nervous behavior and provided conflicting travel itineraries.
- After initial contact, the officer asked to search the vehicle; Zamudio-Hernandez refused consent but agreed to a drug dog sniff.
- A drug dog alerted; officers searched the truck and found a hidden cash compartment, $16,000, and a handgun; currency linked to a prior controlled purchase.
- Auten testified that Quintero-Felix and Zamudio-Hernandez delivered methamphetamine to her in Fort Dodge in four transactions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Reasonableness of extended stop | Quintero-Felix contends the stop was unreasonably prolonged. | Quintero-Felix argues continued detention was justified by consent or reasonable suspicion. | Reasonable suspicion or consent supported the extension; suppression denied. |
| Sufficiency of evidence for conspiracy and aiding and abetting | Quintero-Felix contends evidence fails to prove conspiracy and participation. | Quintero-Felix argues testimonies are insufficient to prove joined conspiracy and assistance. | Evidence sufficient; convictions affirmed. |
Key Cases Cited
- United States v. Barragan, 379 F.3d 524 (8th Cir. 2004) (time-limited traffic-stop extensions permissible for routine tasks)
- United States v. McCarty, 612 F.3d 1020 (8th Cir. 2010) (consent to questions during traffic stop may extend encounter)
- United States v. Flores, 474 F.3d 1100 (8th Cir. 2007) (totality of circumstances governs reasonableness of prolonged stop)
- United States v. Jones, 269 F.3d 919 (8th Cir. 2001) (consent analysis in traffic-stop encounters depends on facts)
- United States v. Suitt, 569 F.3d 867 (8th Cir. 2009) (reasonableness of detention length is fact-intensive)
- United States v. Lyons, 486 F.3d 367 (8th Cir. 2007) (long drug-dog wait can be reasonable detention)
- United States v. Bloomfield, 40 F.3d 910 (8th Cir. 1994) (extreme nervousness may contribute to reasonable suspicion)
- United States v. Brown, 345 F.3d 574 (8th Cir. 2003) (conflicting stories may justify expanded stop)
- United States v. Munoz, 590 F.3d 916 (8th Cir. 2010) (consent may be inferred from defendant's actions during questioning)
- United States v. Jiminez, 487 F.3d 1140 (8th Cir. 2007) (conspiracy elements include knowledge and voluntary joining)
- United States v. Blaylock, 421 F.3d 758 (8th Cir. 2005) (aiding-and-abetting standard requires participation and intent)
- United States v. Buckley, 525 F.3d 629 (8th Cir. 2008) (jury credibility in conspiracies may rely on cooperating witnesses)
- United States v. Cain, 487 F.3d 1108 (8th Cir. 2007) (conspiracy may be proven by direct or circumstantial evidence)
- United States v. Ruiz-Zarate, 678 F.3d 683 (8th Cir. 2012) (mere presence with knowledge of drug sale is insufficient)
- United States v. Thompson, 686 F.3d 575 (8th Cir. 2012) (unexplained cash and firearms support drug-distribution inference)
- United States v. $404,905.00 in U.S. Currency, 182 F.3d 643 (8th Cir. 1999) (cash linked to drug transactions supports conspiracy inference)