United States v. Madden
682 F.3d 920
10th Cir.2012Background
- Madden pleaded guilty to one count of felon in possession of a firearm and reserved appellate rights on suppressions and preindictment delay.
- Officers questioned Madden when his car, parked in a Grider’s loading area, appeared illegally parked and he lacked a license; he was detained in the patrol car for information processing.
- A search of Madden’s vehicle yielded a firearm and magazines; Madden was arrested for two outstanding municipal warrants.
- State court suppressed part of the search as improper impoundment; Madden later pleaded guilty to separate state drug charges and was released in 2008.
- Federal indictment followed in 2009 based on the 2005 Grider’s parking lot incident; Madden challenged suppression and indictment delay.
- District court denied both motions; Madden then pled guilty under a conditional plea, preserving appellate issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the detention/search violated the Fourth Amendment | Madden | Balderrama | Detention reasonable; search justified by good-faith exception |
| Whether the good-faith exception salvages the vehicle search | Madden | Balderrama | Good-faith exception applies; search affirmed |
| Whether preindictment delay violated due process or speedy trial rights | Madden | United States | Delay did not violate Fifth or Sixth Amendments |
| Whether preindictment delay violated Sixth Amendment speedy-trial right | Madden | United States | Speedy-trial right not violated; attached at federal arrest in 2009 |
Key Cases Cited
- United States v. Ringold, 335 F.3d 1168 (10th Cir. 2003) (three-tier police-citizen encounters; consensual, detentions, arrests)
- Florida v. Bostick, 501 U.S. 429 (Supreme Court 1991) (consensual encounters may become seizures depending on compliance pressure)
- Arizona v. Gant, 556 U.S. 332 (Supreme Court 2009) (limits search-incident-to-arrest to vehicle evidentiary relevance)
- United States v. McCane, 573 F.3d 1037 (10th Cir. 2009) (good-faith exception applies to searches based on then-existing precedent)
- United States v. Leon, 468 U.S. 897 (Supreme Court 1984) (good-faith exception; objective reasonableness governs suppression inquiry)
- Davis v. United States, 131 S. Ct. 2419 (Supreme Court 2011) (deterrence and costs considerations; objective reasonableness governs exclusion)