United States v. Matthew Massi
2014 U.S. App. LEXIS 14815
| 5th Cir. | 2014Background
- Massi was arrested for possession with intent to distribute marijuana after a ramp check at Midland Airport, Texas.
- AMOC flagged the flight as suspicious due to route, owner’s drug-trafficking conviction, and Massi’s recent cross-border travel; MPD conducted initial questioning and exterior inspection.
- A canine sniff of the exterior (including luggage) occurred; the dog did not alert.
- Massi denied interior searches; he owned a cardboard box seen on the plane; he later admitted ownership after Sanchez’s statement.
- Agent Howard obtained a search warrant after coordinating with AMOC, the US Attorney’s office, and a magistrate judge; midnight search of the airplane yielded 19 sealed bags of marijuana weighing 10.50 kilograms.
- Massi pleaded guilty conditioned on his right to appeal the denial of the suppression motion; the district court denied the suppression motion and the Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Massi’s detention beyond the ramp check was a Fourth Amendment seizure. | Massi: detention prolonged without reasonable suspicion or probable cause. | Government: initial ramp check justified continued investigation under Terry with evolving reasonable suspicion. | Detention morphed into a de facto arrest without probable cause. |
| Whether the good faith exception salvages the use of the search warrant despite the tainted detention. | Massi: good faith should not validate evidence obtained after unlawful detention. | Government: good faith applies; warrant obtained and executed by officers acting reasonably. | Good faith exception applies to admit the evidence. |
Key Cases Cited
- United States v. Zavala, 541 F.3d 562 (5th Cir. 2008) (probable-cause assessment when detention may become arrest)
- United States v. Michelletti, 13 F.3d 838 (5th Cir. 1994) (standard of review for suppression rulings; any reasonable view supports ruling)
- United States v. Brigham, 382 F.3d 500 (5th Cir. 2004) (reasonableness of stop length and scope under Terry)
- United States v. Gates, 462 U.S. 213 (1983) (probable-cause standard; layered information approach)
- United States v. Mendenhall, 446 U.S. 544 (1980) (test for seizure/arrest expectations)
- United States v. Woerner, 709 F.3d 527 (5th Cir. 2013) (good-faith exception and tainted evidence analysis)
- United States v. McClain, 444 F.3d 556 (6th Cir. 2005) (good-faith exception despite prior Fourth Amendment violation)