United States v. MacIas, 2011 U.S. App. LEXIS 19647

Macias appeals the district court’s denial of suppression of a firearm found during a warrantless search of a truck on I-10 in Pecos County, Texas.
Trooper Barragan stopped Macias for not wearing a seatbelt; the stop was upheld as valid for that traffic violation.
During the stop, Barragan asked extensive questions unrelated to the seatbelt and trip purpose, before running computer checks on licenses and vehicle.
The questioning extended the stop beyond its initial purpose, without a separate, articulable reasonable suspicion of additional criminal activity.
After a lengthy, unlawful detention, Barragan obtained consent to search the truck; the government argued consent was voluntary and independent of the detention.
The district court denied suppression; Macias pleaded guilty conditionally, reserving the right to appeal the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the detention extended beyond its legitimate scope without reasonable suspicion?	Macias contends Barragan extended the stop with unrelated questions.	Barragan argues questions related to trip purpose and other topics were permissible to resolve the stop.	Yes; extended detention without reasonable suspicion violated the Fourth Amendment.
Did the unrelated questioning impermissibly extend the stop duration?	Unrelated questions prolonged the stop without justification.	Questions aided determination of the traffic violation and safety concerns within scope.	Yes; unrelated questioning extended the stop beyond its lawful duration.
Was Macias’s consent to search independent of the illegal detention?	Consent was tainted by the prior unlawful detention and not an independent act of free will.	Consent was voluntary and supported by the six-factor test.	No; consent did not sever the causal link to the unconstitutional detention.
Should the firearm be suppressed as fruits of the unconstitutional detention?	Evidence obtained as a result of the unlawful detention must be suppressed.	Suppression not required if consent were voluntary and attenuated from the detention.	Yes; the firearm and related evidence must be suppressed.

United States v. Brigham, 382 F.3d 500 (5th Cir. 2004) (two-step Terry stop analysis; scope must match initial justification)
United States v. Pack, 612 F.3d 341 (5th Cir. 2010) (unrelated questioning may extend detention only with reasonable suspicion)
United States v. Shabazz, 993 F.2d 431 (5th Cir. 1993) (questions unrelated to stop normally permissible if not extending detention)
United States v. Santiago, 310 F.3d 336 (5th Cir. 2002) (nervousness alone does not establish reasonable suspicion)
United States v. Estrada, 459 F.3d 627 (5th Cir. 2006) (extensive questioning before computer checks; distinguishs from extended detention without suspicion)
United States v. Jones, 234 F.3d 234 (5th Cir. 2000) (detention is a seizure; evaluate custodial intrusion under Fourth Amendment)
United States v. Dortch, 199 F.3d 193 (5th Cir. 1999) (consent attenuated analysis; independence from prior illegality required)
United States v. Chavez-Villarreal, 3 F.3d 124 (5th Cir. 1993) (six-factor voluntariness test for consent after detention)
United States v. Machuca-Barrera, 261 F.3d 425 (5th Cir. 2001) (questioning in immigration context; detention length limits apply)
United States v. Lopez-Moreno, 420 F.3d 420 (5th Cir. 2005) (totality of circumstances in reasonable suspicion evaluation)