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United States v. Oswaldo Vargas
848 F.3d 971
11th Cir.
2017
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Background

  • Alabama trooper Corporal Shone Minor stopped a Ford Freestyle for following too close and lane violations; driver Antonio Castro admitted he had no license.
  • Two minutes and 57 seconds after the stop, Minor told Castro he would issue a written warning.
  • Minor continued routine inquiries (checking licenses, attempting to determine how to legally move the vehicle); neither Castro nor passenger Oswaldo Vargas had a license.
  • About 18 minutes and 34 seconds into the stop (≈15 minutes after announcing the warning), Minor requested and obtained Castro’s consent to search the vehicle.
  • The search revealed cocaine and methamphetamine; Vargas was charged, moved to suppress the evidence, lost, pleaded guilty with preserved appeal, and was sentenced to 123 months.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the traffic stop was unreasonably prolonged after the officer issued a warning Vargas: The stop’s purpose was complete when Minor announced the warning at 2:57, so continuing ~15 more minutes rendered the detention unconstitutional Government/Minor: Continued detention was part of lawful "ordinary inquiries" and necessary because neither occupant could legally drive the vehicle away The court held the continued detention was lawful because inquiries into licensing and taking steps to remove the vehicle were part of the traffic stop mission; consent was obtained while detention remained lawful

Key Cases Cited

  • Rodriguez v. United States, 575 U.S. 348 (2015) (traffic-stop may not be prolonged beyond mission of issuing citation and ordinary inquiries)
  • United States v. King, 509 F.3d 1338 (11th Cir. 2007) (standard of review for suppression rulings: factual findings for clear error, legal application de novo)
Read the full case

Case Details

Case Name: United States v. Oswaldo Vargas
Court Name: Court of Appeals for the Eleventh Circuit
Date Published: Feb 16, 2017
Citation: 848 F.3d 971
Docket Number: 16-14714 Non-Argument Calendar
Court Abbreviation: 11th Cir.