United States v. Steppello
2011 U.S. App. LEXIS 25577
2d Cir.2011Background
- This case involves the government’s appeal of suppression rulings by the district court arising from a narcotics investigation in Utica, New York.
- Szuba identified Steppello as his cocaine supplier after a search and cooperation, revealing a long-running drug distribution pattern and coded transactions.
- Surveillance captured a white male delivering cocaine to Szuba’s residence; Steppello was arrested in Szuba’s driveway after cocaine was found on him.
- A search warrant for Steppello’s residence was supported by an affidavit noting Steppello’s ownership of the SUV and his cocaine distribution activity.
- The district court suppressed the cocaine from Steppello’s person and his statements, and the evidence from the residence, ruling there was no probable cause to arrest.
- The Second Circuit reversed, holding probable cause existed and remanded to a different judge for proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there was probable cause to arrest Steppello | Steppello lacked reliable corroboration and training-based inference undermining probable cause | Totality of circumstances and informant reliability supported probable cause | Probable cause existed; arrest was proper |
| Whether suppression of residence evidence was proper absent probable cause tied to the arrest | Without cocaine from Steppello, probable cause for the warrant failed | Arrest-based probable cause validated the search warrant | Evidence from the residence was admissible (not suppressed) |
| Whether Steppello's statements were admissible as fruits of the arrest | Statements were fruits of an unlawful arrest if arrest lacked probable cause | Arrest was lawful, so statements were admissible | Statements admissible; not suppressed |
Key Cases Cited
- United States v. Gagnon, 373 F.3d 230 (2d Cir. 2004) (informant reliability and corroboration in probable cause; Gagnon controlling here)
- United States v. Delossantos, 536 F.3d 155 (2d Cir. 2008) (totality of the circumstances; trained officers may interpret patterns)
- United States v. Velasquez, 271 F.3d 364 (2d Cir. 2001) (drug transactions and coded language; patterns in narcotics cases)
- United States v. Elmore, 482 F.3d 172 (2d Cir. 2007) (probable cause tied to seizure results and search validity)
- Pescatore v. Pan Am. World Airways, Inc., 97 F.3d 1 (2d Cir. 1996) (remand authority when appearance of bias or improper handling)
- United States v. Robin, 553 F.2d 8 (2d Cir. 1977) (en banc discussion on remanding to different judge)