United States v. Randolph
2011 U.S. App. LEXIS 496
| 8th Cir. | 2011Background
- Detective Stanze and partner surveilled Randolph in a gold Chevrolet Monte Carlo tied to PCP trafficking.
- Randolph visited multiple residences; two months earlier police had information linking the residence to PCP distribution.
- Randolph committed a traffic violation by failing to signal, prompting a uniformed officer to stop the vehicle for investigation and a public drunkenness issue.
- Miller stopped Randolph, who denied ownership of the car; Randolph was frisked, identified, and handcuffed after a criminal history check revealed he was a felon.
- Bryant observed a handgun on the driver’s side floorboard through the window; after being informed Randolph was a felon, Bryant unlocked the door and examined the gun; officers thereafter found PCP and other drugs in the car; Randolph was arrested for felon in possession, public intoxication, and signaling violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the traffic stop supported by probable cause due to a traffic violation? | Randolph argues no valid stop; lacks reasonable suspicion. | Stanze's traffic violation (failure to signal) justified stop and investigation. | Yes; failure to signal supports probable cause for the stop. |
| Was the search of the Monte Carlo permissible as a search incident to arrest under Arizona v. Gant? | Bryant’s entry into the car was improper absent knowing arrestee was felon. | Arrestee was a felon and gun was in car; search incident to arrest valid. | Yes; once gun visible and felon status acknowledged, search justified under Gant. |
| Does Randolph have standing to challenge the search of the Monte Carlo? | Randolph maintained a possessory/privacy interest in the vehicle. | Randolph disclaimed ownership; no reasonable expectation of privacy. | No standing; Randolph lacked a legitimate expectation of privacy in the car. |
Key Cases Cited
- Thornton v. United States, 541 U.S. 615 (2004) (limits on timing of stops after a vehicle has ceased)
- Whren v. United States, 517 U.S. 806 (1996) (probable cause for traffic stops for any violation; objective standard)
- Adler, 590 F.3d 581 (8th Cir. 2009) (review of district court factual findings; reasonable suspicion concepts)
- Bloomfield, 40 F.3d 910 (8th Cir.1994) (any traffic violation can support a stop; minor violation suffices)
- Pena-Ponce, 588 F.3d 579 (8th Cir.2009) (even minor violations can provide probable cause for a stop)
- Luna, 368 F.3d 876 (8th Cir.2004) (reasonable cause for stop based on traffic behavior)
- Rodriguez-Lopez, 444 F.3d 1020 (8th Cir.2006) (failure to signal can establish probable cause)
- Katz v. United States, 389 U.S. 347 (1967) (reasonable expectation of privacy; personal rights)
- Arizona v. Gant, 129 S. Ct. 1710 (2009) (limits on vehicle searches incident to arrest; must be within reach or contain evidence of offense)
- United States v. Washington, 197 F.3d 1214 (8th Cir.1999) (Fourth Amendment rights are personal; standing analysis)