United States v. Mark Noonan, 745 F.3d 934

Shortly after bars closed at ~2:30 a.m., Deputy Kennedy observed Noonan driving a Cadillac slowly and making multiple left turns and a U-turn on Highway 20 and Mile Hill Lane, an area with recent storage-shed burglaries.
Kennedy followed, stopped the vehicle (no traffic violation observed), ran a license check and learned of an outstanding arrest warrant for Noonan; Kennedy arrested and handcuffed him.
A pat-down revealed a meth pipe; Kennedy then retrieved a black backpack from the car and found pseudoephedrine, ether, sulfuric acid, and a jar with a suspicious substance and ammonia odor.
Before searching the car, while Noonan was in the patrol car and handcuffed but before Miranda warnings, Kennedy questioned whether there was meth or a "one-pot" in the bag; Noonan volunteered that there was ether and other materials.
The district court denied Noonan’s motion to suppress physical evidence and his pre-Miranda statements; Noonan appealed both reasonable-suspicion and Miranda issues.

Issue	Noonan's Argument	Government's Argument	Held
Whether the initial stop was supported by reasonable suspicion	Stop was unjustified; factors were consistent with innocent travel	Totality of circumstances (time, slow/evasive driving, multiple turns, local burglaries) furnished reasonable suspicion	Stop was justified; suppression denied
Whether pre-warning statements were product of custodial interrogation requiring Miranda warnings	Questions elicited incriminating statements and were custodial interrogation; statements should be suppressed	Questions were aimed at safety concerns about a possible meth lab; public-safety exception applies	Statements admissible under the public-safety exception to Miranda

Terry v. Ohio, 392 U.S. 1 (permitting brief investigative stops based on reasonable suspicion)
Ornelas v. United States, 517 U.S. 690 (reasonable-suspicion review is de novo)
Arizona v. Arvizu, 534 U.S. 266 (totality-of-the-circumstances test for reasonable suspicion)
United States v. Winters, 491 F.3d 918 (8th Cir.: officer may stop automobile on reasonable suspicion)
New York v. Quarles, 467 U.S. 649 (public-safety exception to Miranda)
United States v. Liddell, 517 F.3d 1007 (8th Cir.: public-safety questioning about weapons/drug paraphernalia allowed)
United States v. Luker, 395 F.3d 830 (8th Cir.: officers may ask safety-related questions before Miranda warnings)
United States v. Ellefson, 419 F.3d 859 (discussing dangers of meth manufacture to public safety)
United States v. Walsh, 299 F.3d 729 (permitting safety-based questioning about dangerous contraband)