United States v. Jesus Uribe
2013 U.S. App. LEXIS 2941
7th Cir.2013Background
- Uribe drove a blue Nissan Altima with Utah plates on I-70 in Indiana; color did not indicate wrongdoing or traffic violations.
- A color registration discrepancy (blue car vs white car in registration) prompted Deputy Simmons to stop the vehicle to check registration compliance.
- After the stop, a canine alert led to a search; nearly a pound of heroin was found and Uribe was indicted for intent to distribute.
- Uribe moved to suppress, arguing the stop lacked reasonable suspicion based on color discrepancy alone; district court agreed.
- This appeal asks whether a color discrepancy alone can create reasonable suspicion; the government argued additional theories (e.g., vehicle theft, registration violation).
- Court analyzes legality of the stop under Fourth Amendment and concludes color discrepancy alone does not create reasonable suspicion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does a color discrepancy alone create reasonable suspicion? | Uribe | Uribe | Color discrepancy alone insufficient for reasonable suspicion |
| Can a color discrepancy plus an alleged registration violation justify a stop? | Uribe | Uribe | Registration-provision theory fails because Utah-registered vehicle not subject to Indiana provision |
| Was the government's proposed reliance on timing or other factors lawful? | Uribe | Uribe | Timing and other factors did not elevate suspicion |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (1979) (random vehicle stops for document checks violate Fourth Amendment absent reasonable suspicion)
- Terry v. Ohio, 392 U.S. 1 (1968) (establishes reasonable suspicion standard for stop-and-frisk)
- Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances approach for probable cause/suspicion)
- United States v. Sokolow, 490 U.S. 1 (1989) (totality of circumstances governs reasonable suspicion; not innocent/guilty labeling)
- United States v. Hicks, 531 F.3d 555 (7th Cir. 2008) (applies totality-of-circumstances; confirms need for articulable facts)
- Reid v. Georgia, 448 U.S. 438 (1980) (no reasonable suspicion where circumstances describe large category of innocents)
- United States v. Longmire, 761 F.2d 411 (7th Cir. 1985) (preponderance standard for reasonable suspicion; weight of evidence matters)
- United States v. Dennis, 115 F.3d 524 (7th Cir. 1997) (articulable characteristics required for suspicion)