United States v. Madrid
2013 U.S. App. LEXIS 7755
| 10th Cir. | 2013Background
- 911 tip initially reported a suspicious subject in the Rinaldi Apartments parking lot, later described as a fight with two men and a woman near two cars.
- Police arrived; Lt. Stoyell recognized Madrid, a prior felon, and stopped Madrid’s car to investigate potential fight and for officer safety.
- Officer Sanchez, viewing a rifle case in the back seat, suspected a rifle; rifle was later removed and found to be capable of containing a rifle.
- Madrid was detained and questioned; he provided license and registration; he was cuffed and the rifle was held as evidence; Madrid later agreed to cooperate but did not materialize cooperation.
- Madrid was indicted on felon-in-possession and related charges; he moved to suppress the rifle; district court denied suppression; Madrid pled guilty to felon-in-possession while preserving appeal rights.
- On appeal, Madrid challenges the denial of suppression, arguing the stop lacked reasonable suspicion and was unlawful under the Fourth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the stop justified at inception? | Madrid contends lack of reasonable suspicion. | United States argues contemporaneous facts and flight behavior supported suspicion. | Yes; stop justified at inception. |
| Did Madrid’s exit attempt affect the reasonable suspicion analysis? | Madrid argues no basis to infer flight or evasion by him. | Exit attempts are relevant objective indicators under Terry/Arvizu. | The exit attempt properly supported reasonable suspicion. |
| Does the intrusion balance against governmental interests in this context? | Madrid asserts the intrusion was minimal but unfounded. | Government interests in solving crime and public safety justified a brief stop. | Intrusion brief; strong government interest; stop reasonable. |
| Was the anonymous 911 tip sufficiently reliable to support the stop? | Anonymous tip with limited identifying information undermines reliability. | Totality of circumstances including firsthand contemporaneous observation and corroboration supports reliability. | Tip bore sufficient indicia of reliability to justify the stop. |
Key Cases Cited
- Terry v. Ohio, 292 U.S. 1 (Supreme Court) (established two-pronged Terry stop framework)
- Whren v. United States, 517 U.S. 806 (S. Ct. 1996) (temporary traffic stops are seizures subject to Fourth Amendment scrutiny)
- Sokolow, 490 U.S. 1 (Supreme Court 1989) (reasonable suspicion must be based on totality of circumstances)
- Arvizu, 534 U.S. 266 (Supreme Court 2002) (totality of circumstances governs reasonable suspicion)
- J.L. v. United States, 529 U.S. 266 (Supreme Court 2000) (anonymous tips require indicia of reliability unless corroborated)
- Chávez, 660 F.3d 1215 (10th Cir. 2011) (tip reliability factors include corroboration and firsthand knowledge)
- Copening, 506 F.3d 1241 (10th Cir. 2007) (uncorroborated tips gain weight when corroboration exists)
- Brown, 496 F.3d 1070 (10th Cir. 2007) (anonymous but nonanonymous-like tips with identifying details can be reliable)