United States v. Murphy
2011 U.S. Dist. LEXIS 45143
N.D.N.Y.2011Background
- June 2, 2010, Murphy and Webster are in a gray 2002 Honda Accord traveling on I-70 in Kansas with a drug investigation ongoing; Trooper Stahl positioned in a turnaround planned as a decoy to stop vehicles at Exit 322; MVR and audio records show the stop and interactions; officers discovered a hidden compartment in the Honda's trunk containing cocaine after a search; initial stop and questioning occurred alongside the highway; court later suppresses all evidence and statements due to unlawful seizure and defective Miranda warnings.
- MVR units auto-record when certain events occur and include pre-event footage; evidence showed potential misalignment between Trooper Stahl’s testimony and video/audio recordings.
- Disputes over whether Webster signaled at Exit 322 and whether Stahl could observe the traffic infraction from the turnaround given distance and terrain; topography and obstructions allegedly prevented a clear view, undermining probable cause or reasonable suspicion.
- The Government argues the stop could be justified by observed traffic infractions or independent probable cause; the Court finds the stop unconstitutional and suppresses subsequent searches and statements.
- Post-stop consent to search is contested for attenuation; the court finds taint from the illegal stop cannot be dissipated sufficiently to permit the search.
- Miranda warnings were inadequately administered; promises of waivers were not properly conveyed, so statements made at the scene and at Alma/Wabaunsee Jail are suppressed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Honda stop was a valid seizure | Government: stop justified by observed traffic infraction | Murphy/Webster: no valid observation or probable cause | Unconstitutional seizure; stop invalid. |
| Whether the stop was justified by probable cause or reasonable suspicion | Government: traffic violation justified stop | Defendants: no observable infraction from turnaround | Not supported; stop lacking valid basis. |
| Whether consent to search was admissible after an unlawful stop | Government: taint attenuated by intervening factors | Consent tainted by illegal stop | Consent not attenuated; suppress evidence. |
| Whether statements were obtained in violation of Miranda rights | Government: warnings given; waivers valid | Warnings inadequate; no valid waiver | Statements suppressed; Miranda violations found. |
| Whether severance was warranted or moot | Government: severance unnecessary | Severance needed to protect rights | Denial as moot; Bruton issues moot because statements suppressed. |
Key Cases Cited
- Delaware v. Prouse, 440 U.S. 648 (1979) (probable cause or reasonable suspicion required for traffic stops)
- Scopo v. United States, 19 F.3d 777 (2d Cir. 1994) (traffic stop seizure framework; requirement of justification)
- Wong Sun v. United States, 371 U.S. 471 (1963) (fruit of the poisonous tree; attenuation analysis)
- United States v. Jaswal, 47 F.3d 539 (2d Cir. 1995) (requirements for valid Miranda waivers)
- Kaupp v. Texas, 538 U.S. 626 (2003) (factors for dissipating taint in tainted stops)
- United States v. Montilla, 928 F.2d 583 (2d Cir. 1991) (attenuation and taint analysis after illegal seizure)
- United States v. Restrepo, 890 F. Supp. 180 (E.D.N.Y. 1995) (attenuation factors in suppression analysis)
- United States v. Matlock, 415 U.S. 164 (1974) (Fourth Amendment burden-shifting on suppression)
- United States v. Arboleda, 633 F.2d 985 (2d Cir. 1980) (burden-shifting in suppression hearings)