United States v. Mata-Peña, 233 F. Supp. 3d 281

Background

On June 28, 2016 police stopped a Toyota Tacoma for an alleged illegal lane change; Mata was driving and Ramos (the vehicle owner) was front-seat passenger.
Through the open passenger window an officer observed a few inches of a newspaper-wrapped rectangular package protruding from an unzipped CD binder inside an open box on the rear seat; the officer believed it looked like a kilo of cocaine, opened the rear passenger door, removed and unwrapped it, and discovered cocaine.
After that initial seizure the officers opened other binders and boxes in the rear seat, ultimately recovering six kilograms of cocaine; at the stationhouse an inventory-type search produced a .40-caliber pistol, magazines, and cash.
Defendants Mata and Ramos were indicted for drug and firearms offenses; Mata moved to suppress the evidence as the product of Fourth Amendment violations, and Ramos joined the motion.
The court found the warrantless search and seizure of the package visible in the binder violated the Fourth Amendment because the partially exposed sliver did not give probable cause to seize or to manipulate the package into full view.
The court suppressed all evidence recovered from the truck as fruits of the poisonous tree, but limited suppression to Ramos because Mata failed to establish Fourth Amendment standing in the vehicle.

Issues

Issue	Government's Argument	Defendants' Argument	Held
Was the initial warrantless seizure/search of the partially-exposed package justified under the plain-view (or automobile) exception?	Officer saw a book/brick-shaped, newspaper-wrapped object that, by his training, matched kilo packaging for cocaine; plain view allowed seizure.	The exposed sliver was too minimal and nondescript to make the incriminating character "immediately apparent;" seizure and manipulation were unlawful.	Not justified: the partial exposure did not supply probable cause and the officer impermissibly moved the package into view.
Were subsequent searches/seizures (other kilos, gun, magazines) admissible or fruits of the initial illegality?	Initial seizure produced probable cause and arrest, justifying further searches and an inventory.	Subsequent recoveries were discovered only by exploitation of the illegal initial seizure; no attenuation.	Fruits of the poisonous tree: all evidence from the truck suppressed (no attenuation shown).
Does the good-faith exception save the evidence?	Agent acted in good faith and/or objectively reasonable belief the package was contraband.	Any well-trained officer would have known the partial exposure did not establish probable cause; cannot rely on ignorance.	Good-faith exception does not apply; suppression appropriate.
Do defendants have Fourth Amendment standing to seek suppression? (Mata v. Ramos)	—	Ramos: owner and passenger — standing. Mata: only the authorized driver; no ownership, repeated use, or other privacy interest shown.	Ramos has standing; evidence suppressed as to Ramos. Mata lacks standing; evidence not suppressed as to Mata.

Key Cases Cited

United States v. White, 804 F.3d 132 (1st Cir.) (automobile-exception standards for vehicle searches)
United States v. Silva, 742 F.3d 1 (1st Cir.) (probable cause for vehicle searches)
Arizona v. Hicks, 480 U.S. 321 (plain-view seizure invalid where officers had to move object to gain incriminating information)
United States v. Ross, 456 U.S. 798 (search of vehicle and containers permitted when probable cause exists)
United States v. Paneto, 661 F.3d 709 (1st Cir.) (plain-view seizure requires lawful vantage point, probable cause, and right of access)
Davis v. United States, 564 U.S. 229 (exclusionary rule aims to deter misconduct; not automatic)
Herring v. United States, 555 U.S. 135 (good-faith exception and attenuation analysis)