United States v. Juan Collazo
818 F.3d 247
6th Cir.2016Background
- On Oct. 9, 2013, West Tennessee Drug Task Force Special Agent Preston Hill stopped Juan Collazo’s van on I-40 for allegedly following a tractor-trailer too closely; Collazo’s wife Cinthia was a front-seat passenger.
- Hill estimated the van travelled near 70 mph and was less than four car lengths (about a three-second gap) behind the truck; video (no audio) partly recorded the stop.
- During the stop Hill asked for license/registration, spoke with both occupants, and waited on dispatch for a license check; the traffic-stop portion concluded after ~21 minutes.
- Agent David Montgomery separately questioned Cinthia, who appeared nervous and eventually admitted something illegal was in her purse; he found a prescription bottle and loose Suboxone strips.
- After the Suboxone discovery, officers obtained consent(s) according to their testimony (Collazo disputed consenting), searched the van, and found 3 kg of cocaine during the stop and 14 kg later; Collazo was indicted for conspiracy to possess ≥5 kg cocaine.
- The district court denied Collazo’s motion to suppress; Collazo conditionally pleaded guilty and appealed the suppression ruling; the Sixth Circuit affirmed.
Issues
| Issue | Collazo's Argument | Government's Argument | Held |
|---|---|---|---|
| Whether Hill had probable cause to stop the van for following too closely | No—insufficient evidence of speed/distance; video line segments show ~160 ft gap (≈9 car lengths) | Yes—Hill observed <4 car lengths and ~3-second gap at highway speed; Manual’s car-length/four-second rules support probable cause | Stop was supported by probable cause for violating Tenn. Code Ann. § 55-8-124(a) |
| Whether the stop was unconstitutionally prolonged beyond issuance of warning | Yes—detention continued past mission and was unreasonable | No—21 minutes was reasonable to complete stop; questioning Cinthia and waiting on dispatch were related tasks | 21-minute stop to issue warning was reasonable under the circumstances |
| Whether the continued detention after 21 minutes violated the Fourth Amendment | Continued detention unlawful | Montgomery developed reasonable suspicion (Cinthia’s behavior, inconsistent travel story, admission about illegal item, purchase of Suboxone strips) before 21 minutes elapsed | Continued detention was justified by reasonable suspicion developed during the stop |
| Whether officers had probable cause to search the van (warrantless) | No—Suboxone bottle could explain strips; consent disputed; policy required written consent | Yes—Cinthia’s admission, discovery of loose Suboxone and her purchase admission, inconsistent stories, and behavior gave probable cause to search the vehicle | Officers had probable cause to search the van; court need not decide consent issue |
Key Cases Cited
- United States v. Blair, 524 F.3d 740 (6th Cir. 2008) (traffic-stop standards and scope)
- United States v. Quinney, 583 F.3d 891 (6th Cir. 2009) (standard of review for suppression rulings)
- United States v. Pritchett, 749 F.3d 417 (6th Cir. 2014) (view facts in light most favorable to district court)
- United States v. Sanford, 476 F.3d 391 (6th Cir. 2007) (probable-cause/reasonable-suspicion discussion for traffic stops)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (a stop cannot be prolonged beyond completion of mission absent reasonable suspicion)
- United States v. Lyons, 687 F.3d 754 (6th Cir. 2012) (warrantless vehicle-search probable-cause rule)
- United States v. Ross, [citation="300 F. App'x 386"] (6th Cir. 2008) (passenger handing contraband supports probable cause to search vehicle)
- United States v. Carter, 779 F.3d 623 (6th Cir. 2015) (treating Suboxone as a controlled substance)