United States v. Margarito Saucedo, 688 F.3d 863

Saucedo stopped Jan 11, 2010 for expired registration on a Peterbilt; Miller finds Saucedo’s license invalid.
Saucedo consents to search after officer asks about weapons/drugs and Saucedo volunteers permission to search.
Miller’s team observes suspicious items; canine unit is summoned; Saucedo remains in squad car during search.
Search proceeds from trailer (empty) to cab; an alcove hidden compartment is discovered by removing molding and screws.
Hidden compartment contains 10 kilograms of cocaine; Saucedo arrested; district court denies suppression; Saucedo convicted on conspiracy to possess with intent to distribute cocaine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consent to search scope extended to hidden compartment	Saucedo argues consent limited scope; hidden compartment exceeded consent	Saucedo asserts general consent allows only obvious areas	Search within scope of consent; hidden compartment permissible under broad consent

Florida v. Jimeno, 500 U.S. 248 (U.S. Supreme Court 1991) (scope of consent defined by expressed object; containers within the car may be searched if plausible)
United States v. Jackson, 598 F.3d 340 (7th Cir. 2010) (reasonableness of scope of consent determined from totality of circumstances)
United States v. Torres, 32 F.3d 225 (7th Cir. 1994) (open a compartment with a screwdriver; not a dismantling of the vehicle)
United States v. Garcia, 897 F.2d 1413 (7th Cir. 1994) (dismantling door panels can exceed consent; distinguish from screwdriver use)
United States v. Calvo-Saucedo, 409 F. App’x 21 (7th Cir. 2011) (broad consent to search may broaden by watching but not protest; removal within scope)
United States v. Garcia, 604 F.3d 186 (5th Cir. 2010) (addressed search of hidden compartment; within scope under general consent)