United States v. Quardarius Jalouis Demetric Arkeem Holley
709 F. App'x 602
| 11th Cir. | 2017Background
- Officers stopped Holley’s rental car for failing to fully stop at a stop sign and for allegedly excessively dark window tint under Florida law.
- Holley exited the vehicle, ignored commands, ran toward a nearby house, and was tasered and handcuffed after resisting.
- While one officer detained Holley, the other approached the vehicle, opened the driver’s door to check for occupants, to roll down the window to test tint darkness, and to retrieve registration/insurance information.
- Upon opening the door the officer immediately saw a handgun between the driver’s seat and center console and detected a strong odor of marijuana.
- A subsequent search of the vehicle recovered crack cocaine, powder cocaine, marijuana, and the handgun; Holley moved to suppress these items.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether opening the car door to test window tint violated the Fourth Amendment | Holley: opening the door was an unlawful search not justified by Class | Government: Class permits limited intrusions related to vehicle regulation and officer safety | Court: Opening the door was reasonable under Class (served officer safety, minimal intrusion, tied to the stop) |
| Whether the initial traffic stop was lawful | Holley: stop invalid? (implicit challenge) | Government: stop was supported by observed stop-sign violation and apparent illegal tint | Court: stop valid based on traffic violation and tint observation |
| Whether discovery of the gun and odor justified a vehicle search | Holley: evidence should be suppressed as product of unlawful search | Government: gun in plain view and odor of marijuana provided probable cause for full search | Court: once door legally opened, gun and odor gave probable cause to search vehicle |
| Whether suppression of evidence was required | Holley: all seized evidence must be suppressed | Government: evidence admissible due to lawful stop, Class-based intrusion, and ensuing probable cause | Court: suppression denied; convictions affirmed |
Key Cases Cited
- New York v. Class, 475 U.S. 106 (1986) (upholding limited intrusion to inspect VIN and recognizing diminished privacy in regulated vehicle parts tied to officer safety)
- Pennsylvania v. Mimms, 434 U.S. 106 (1977) (police may order driver out of car during traffic stop to protect officer safety)
- United States v. McCullough, 851 F.3d 1194 (11th Cir.) (standard of review for suppression rulings)
- United States v. Pierre, 825 F.3d 1183 (11th Cir.) (probable cause supports traffic stop for observed violations)
- United States v. Holt, 777 F.3d 1234 (11th Cir.) (scope of lawful on-scene actions must be reasonably related to stop)
- United States v. Caraballo, 595 F.3d 1214 (11th Cir.) (appellate court may affirm suppression denial on any record-supported ground)
- United States v. Stanfield, 109 F.3d 976 (4th Cir.) (discussing officer safety risks from darkly tinted windows)