126 F.4th 432
6th Cir.2025Background
- Shawn Lamar Peake-Wright was a passenger in a car stopped by Kalamazoo police due to the driver’s suspended license and outstanding arrest warrant.
- During the stop, Peake-Wright behaved suspiciously: turning away from the officer, removing his jacket despite cold weather, and repeatedly disobeying instructions.
- Officers were aware of Peake-Wright’s prior criminal history, including firearm offenses.
- After a drug dog did not alert to the presence of drugs, but following continued suspicious behavior, officers searched Peake-Wright’s jacket and found a loaded pistol.
- Peake-Wright moved to suppress the firearm evidence, claiming the search and prolonged stop were unlawful; the district court denied the motion.
- On appeal, he challenged the length of the stop and the existence of probable cause for the search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prolonged traffic stop | Stop lasted beyond mission; became unlawful | Behavior justified extended detention | Stop was reasonably prolonged |
| Probable cause to search | No probable cause after dog did not alert | Suspicious actions & criminal history gave cause | Probable cause existed under totality |
| Application of auto exception | Warrant was required for jacket search | Auto exception applied due to probable cause | Search valid under auto exception |
| Scope of search | Scope should be limited; jacket involvement unclear | Focus on jacket tied to suspicious conduct | Jacket search specifically was justified |
Key Cases Cited
- Rodriguez v. United States, 575 U.S. 348 (duration of traffic stops must be tied to mission and may not be prolonged without independent reasonable suspicion)
- California v. Carney, 471 U.S. 386 (automobile exception to warrant requirement justified by mobility and reduced privacy expectations)
- California v. Acevedo, 500 U.S. 565 (probable cause to search a container in a vehicle permits warrantless search of that container)
- United States v. Sharpe, 470 U.S. 675 (examination of police diligence key to assessing reasonable stop duration)
- Arizona v. Johnson, 555 U.S. 323 (allows unrelated questioning during traffic stops that does not extend their duration)
- Illinois v. Caballes, 543 U.S. 405 (dog sniffs are permissible during lawful traffic stops)