United States v. Rodgers
2011 U.S. App. LEXIS 18564
| 9th Cir. | 2011Background
- On December 16, 2009, at ~3:30 a.m., Moody stopped Rodgers’ car in a high-crime area after observing a color discrepancy between the car’s registration and its appearance, prompting concern the car could be stolen.
- Rodgers was with a young woman (S.F.) who appeared much younger than Rodgers; Moody suspected potential underage prostitution.
- Moody separated Rodgers and S.F. to investigate S.F.’s identity, requesting identification; S.F. claimed she had none, provided a name, and claimed she was 19.
- Moody tested the provided identity against an outstanding arrest warrant; the name matched but the birth year suggested potential age discrepancy; backup officers were called.
- Rodgers and S.F. were detained; Moody then conducted a search of Rodgers’ car, uncovering drugs, cash, and a firearm, leading to arrest and charges against Rodgers.
- Rodgers moved to suppress the physical evidence and statements; the district court credited Moody’s testimony as fully believable but did not make explicit findings on probable cause for the vehicle search; on appeal, the court reversed the suppression ruling on the vehicle search and remanded, with a dissent questioning probable cause for the search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the stop lack reasonable suspicion to justify detention? | Rodgers argues color discrepancy and high-crime area were innocuous. | Rodgers asserts insufficient objective facts for reasonable suspicion. | Assumed, without deciding, that reasonable suspicion supported the stop. |
| Was Moody’s extended detention justified by evolving facts? | Rodgers contends the stop was unlawfully prolonged. | Moody had continuing, particularized grounds as more facts emerged. | Yes; the detention was permissible as new grounds for suspicion continued to unfold. |
| Was there probable cause to search Rodgers’ vehicle for S.F.’s identification? | Rodgers contends no probable cause existed to search the car for identification. | Moody was justified by probable cause to believe evidence of a crime (identification) could be found. | No; there was not probable cause to believe the vehicle contained evidence of a crime, so the vehicle search was unlawful. |
Key Cases Cited
- United States v. Ross, 456 U.S. 798 (1982) (automobile exception to warrant requirement; probable cause to search a vehicle)
- Arizona v. Gant, 556 U.S. 332 (2009) (limits on vehicle searches incident to arrest; reasonable belief search area contains evidence)
- Brooks v. United States, 610 F.3d 1186 (9th Cir. 2010) (probable cause to search a vehicle must be tied to the place searched and the crime sought)
- United States v. Maddox, 614 F.3d 1046 (9th Cir. 2010) (standard of review for suppression rulings; de novo review with fact findings reviewed for clear error)
- United States v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances approach to probable cause)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause requires more than mere suspicion; totality of circumstances)