United States v. Miranda-Sotolongo, 2016 U.S. App. LEXIS 11816

Background

On Sept. 2, 2013 Officer Jared Johnson stopped Alexis Miranda‑Sotolongo after seeing an Indiana temporary registration tag placed in the license‑plate holder and checking the tag number in a law‑enforcement database.
Two independent database queries (the officer’s and a dispatcher’s) returned no record for the temporary registration number; the officer stopped the car to investigate whether the tag was forged or the vehicle stolen/unregistered.
During the stop Miranda‑Sotolongo admitted driving on a suspended license and was arrested; an inventory search later produced two firearms leading to conviction under 18 U.S.C. § 922(g)(1).
Miranda‑Sotolongo moved to suppress the guns, arguing the traffic stop lacked reasonable suspicion and that the database check was an unconstitutional search.
The district court denied suppression; the defendant was convicted and sentenced with several special supervised‑release conditions he later challenged on appeal as vague and insufficiently justified.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of database check / whether checking visible registration against public records is a Fourth Amendment search	Government: checking a publicly visible registration number against public law‑enforcement records is not a Fourth Amendment search and may be relied on to justify a stop	Miranda‑Sotolongo: the database inquiry was an unlawful search because it was a random spot check or based on a mistaken view of Indiana law; thus the stop lacked a lawful basis	The database check is not a Fourth Amendment search; officer could rely on absence of record to form reasonable suspicion and the stop was justified
Reasonable suspicion for the traffic stop based on absence of registration in database	Government: two independent checks showed no registration record, plus the tag looked homemade — together these facts gave reasonable suspicion the vehicle was stolen or unregistered	Miranda‑Sotolongo: absence from database has innocent explanations (recent purchase, holiday delay); government failed to show database reliability so absence cannot support reasonable suspicion	Court: reasonable suspicion existed here because the totality of circumstances (no database record + suspicious tag appearance + officer experience) justified the stop; suppression denial affirmed
Whether officer’s initial attention to tag placement (mistaken view of Indiana law) vitiates stop	Government: officer’s initial observation only prompted a database check; the stop rested on the database results, not the legal mistake	Miranda‑Sotolongo: officer’s mistaken belief about tag placement was the true basis for the stop, and an unreasonable legal mistake cannot justify detention	Court: need not decide if the mistake was reasonable because officer did not stop until database checks failed; stop therefore rests on database absence, not the legal mistake
Vagueness and justification of special supervised‑release conditions	Government: conditions (restrictions on excessive alcohol, mood‑altering substances, testing, and obtaining GED) were appropriate and customary	Miranda‑Sotolongo: conditions are unconstitutionally vague or not adequately justified by § 3553(a) factors; he objected on appeal though not below	Court: recent precedent requires vacating these specific conditions as vague or in need of clarification and remanding for reconsideration (vacated and remanded)

Key Cases Cited

Terry v. Ohio, 392 U.S. 1 (1968) (establishes standard for investigative stops and "specific and articulable facts" requirement)
United States v. Cortez, 449 U.S. 411 (1981) (totality‑of‑the‑circumstances standard for reasonable suspicion)
United States v. Sokolow, 490 U.S. 1 (1989) (degree of suspicion required for Terry stops is lower than probable cause)
Delaware v. Prouse, 440 U.S. 648 (1979) (random spot checks of motorists impermissible absent individualized suspicion)
Heien v. North Carolina, 574 U.S. 54 (2014) (Fourth Amendment tolerates reasonable mistakes of law)
Rodriguez v. United States, 575 U.S. 348 (2015) (traffic stops analyzed under Terry framework)
United States v. Uribe, 709 F.3d 646 (7th Cir. 2013) (limits on inferring theft from minor database discrepancies)
United States v. Mounts, 35 F.3d 1208 (7th Cir. 1994) (absence from registration database can support a stop absent evidence database is unreliable)
United States v. Esquivel‑Rios, 725 F.3d 1231 (10th Cir. 2013) (remand where evidence suggested dispatcher told officer temporary tags often don’t return in database searches)
United States v. Siegel, 753 F.3d 705 (7th Cir. 2014) (supervised‑release conditions like "excessive alcohol" and broad ‘‘mood‑altering substance" prohibitions are impermissibly vague)
United States v. Baker, 755 F.3d 515 (7th Cir. 2014) (vacating vague alcohol‑related supervised‑release condition)
United States v. Thompson, 777 F.3d 368 (7th Cir. 2015) (vacating requirement that defendant "obtain his GED" as opposed to "seek" GED)