United States v. Paul Beard, 708 F.3d 1062

Beard was stopped by Arkansas State Trooper Goodman after Beard’s car allegedly violated Arkansas traffic laws (careless driving).
Beard argued the stop was unlawful and sought suppression of over 180 pounds of marijuana found in the trunk, contending the video contradicted Goodman’s account.
The district court denied suppression, crediting Goodman’s testimony over Beard’s and finding the video not dispositive.
The district court held Goodman could have reasonably believed Beard violated the statute based on his driving, validating the stop under the Fourth Amendment and the automobile exception for the subsequent search.
Beard challenged the stop on appeal, arguing the video undermined Goodman’s account and that the stop may have been unlawful.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the initial traffic stop lawful?	Beard asserts the stop lacked reasonable suspicion or justification.	Beard argues the video contradicts Goodman’s description, undermining the stop.	Yes; the court affirmed the stop as supported by Goodman’s account and the circumstances.
Credibility assessors: can the court credit officer over video?	Beard challenges credibility based on video evidence opposing Goodman.	Beard contends video shows a different sequence of events; district court erred in crediting Goodman.	No clear error; the court deferentially reviews credibility findings; video cannot overturn if permissible view supports Goodman.
Whether probable cause existed to search under the automobile exception.	Beard argues lack of lawful stop negates probable cause from odor alone.	Beard concedes odor after window down established probable cause for search.	Yes; odor of marijuana after Beard rolled down the window supplied probable cause to search.
Was the video's limitations fatal to the stop's legality?	Beard claims video renders the stop unlawful.	Beard relies on camera view; the district court’s view is more expansive and credible.	No; the district court’s factual findings were not clearly erroneous given the video’s limitations.

United States v. Donnelly, 475 F.3d 946 (8th Cir. 2007) (standard for reviewing reasonable suspicion and probable cause; clear erroneous if convinced of a mistake)
United States v. Washington, 455 F.3d 824 (8th Cir. 2006) (articulable and reasonable suspicion supports stop for minor traffic violations)
United States v. Mayo, 627 F.3d 709 (8th Cir. 2010) (probable cause to search under automobile exception when contraband probable)
United States v. Peltier, 217 F.3d 608 (8th Cir. 2000) (odor of marijuana can establish probable cause to search)
United States v. VonWald, 638 F.3d 905 (8th Cir. 2011) (when two permissible views exist, choose the district court’s; credibility findings are rarely reviewable)
United States v. Fleck, 413 F.3d 883 (8th Cir. 2005) (suppression not warranted for physical evidence even with Miranda issues if no involuntary statements led to discovery)
United States v. Coleman, 700 F.3d 329 (8th Cir. 2012) (trial court credibility findings virtually unreviewable on appeal)