18 F.4th 76
1st Cir.2021Background:
- On Dec. 12, 2017, Trooper Thomas Pappas followed Arthur Miles on the Maine Turnpike after Miles drove for ~2 miles in the left lane without passing and passed a sign reading 'Keep Right Except to Pass.'
- Trooper ran the plate, learned the car was registered to a Wilkerson at a Dorchester address and recalled a prior drug arrest involving that name on that street.
- Trooper signaled Miles to stop for the left-lane violation; upon approach he smelled marijuana, saw a champagne bottle, and learned Miles’s license was suspended and that he had probation/bail issues.
- Trooper handcuffed Miles, searched the vehicle, and found contraband; Miles was indicted for possession with intent to distribute.
- Miles moved to suppress the statements and physical evidence, arguing the traffic stop was pretextual and lacked reasonable suspicion; the district court denied suppression.
- Miles entered a conditional guilty plea reserving the suppression issue and appealed the denial, arguing the stop was based on a mere hunch tied to the plate-owner’s name.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the traffic stop violated the Fourth Amendment because it was pretextual and lacked reasonable suspicion | Miles: Trooper stopped car based on a hunch from the registered owner’s name, not an objectively reasonable basis | Government/Trooper: Stop was supported by objective facts (left-lane violation); subjective motive irrelevant under Whren | Court: Affirmed — stop objectively reasonable; pretextual motive irrelevant under Whren; suppression denied |
Key Cases Cited
- Whren v. United States, 517 U.S. 806 (1996) (subjective officer intent does not invalidate an objectively justified traffic stop)
- Heien v. North Carolina, 574 U.S. 54 (2014) (Fourth Amendment tolerates reasonable mistakes of law by officers)
- Navarette v. California, 572 U.S. 393 (2014) (reasonable suspicion inquiry is objective and particularized)
- United States v. Simpkins, 978 F.3d 1 (1st Cir. 2020) (appellate review standards for suppression hearing findings)
- United States v. Chhien, 266 F.3d 1 (1st Cir. 2001) (reasonable suspicion must be judged case by case; consider all circumstances)