United States v. Terrence Byrd
679 F. App'x 146
| 3rd Cir. | 2017Background
- Byrd, sole occupant of a rental car, was stopped by state police on a four-lane highway after an officer observed him pass two trucks in the left lane and remain in the left lane during an extended passing maneuver (alleged violation of 75 Pa. Cons. Stat. § 3313(d)).
- Officer noticed the driver’s seat was unusually reclined, followed Byrd, and initiated the traffic stop; dash-cam video and audio recorded the encounter.
- Byrd produced an interim New York license without a photo and a rental agreement that did not list him as renter or permissive driver; computer checks initially returned an alias (James Carter) and later revealed a New Jersey outstanding warrant.
- Officers asked Byrd to move the vehicle for safety, experienced computer connection problems while verifying identity and the warrant, and later asked Byrd to exit the car; Byrd admitted to having a blunt and officers asked for consent to search, asserting consent was given.
- Search of the trunk uncovered heroin and body armor; Byrd moved to suppress, challenging (1) the legality of the initial stop as pretextual, (2) the length/extension of the stop, and (3) his standing to challenge the vehicle search.
- The District Court credited the officer’s traffic-violation testimony, found officers developed reasonable suspicion during the stop, and held Byrd lacked Fourth Amendment standing to challenge the rental-car search because he was not listed on the rental agreement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Legality of initial stop (pretext) | Officer’s video does not show Byrd had time/space to return to right lane; stop was pretextual | Any observed technical traffic violation legitimizes the stop; officer testimony credible | Stop lawful; district court’s factual finding not clearly erroneous; traffic violation reasonable suspicion |
| Length/extension of stop | Officers impermissibly prolonged stop beyond traffic purpose | Identity checks, moving vehicle for safety, resolving alias/warrant, and delays due to computer issues were diligence related to the stop; developing reasonable suspicion justified expansion | Duration reasonable; officers acted with reasonable diligence; later-developed reasonable suspicion justified extension |
| Search consent/standing | Byrd did not consent to search; consent invalid | Byrd, as sole occupant not listed on rental agreement, lacks expectation of privacy and thus standing to challenge the search | Byrd lacks Fourth Amendment standing to challenge search under Third Circuit precedent; court did not reach consent issue |
| Use of outstanding warrant to detain | (Implicit) Detention to verify out-of-state warrant was unlawful prolongation | Discovery of valid out-of-state warrant permits inquiry and can break causal chain for later evidence | Inquiry into warrant was permissible; discovery of warrant further supported officers’ actions |
Key Cases Cited
- United States v. Delfin-Colina, 464 F.3d 392 (3d Cir.) (reasonable-suspicion standard for traffic stops and review standards)
- United States v. Mosley, 454 F.3d 249 (3d Cir.) (technical traffic-code violation legitimizes a stop even if pretextual)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (officers must act with reasonable diligence; scope/duration limits on traffic stops)
- United States v. Lewis, 672 F.3d 232 (3d Cir.) (officer may expand inquiry upon developing reasonable, articulable suspicion)
- United States v. Givan, 320 F.3d 452 (3d Cir.) (same principle on expanding scope of stop)
- Utah v. Strieff, 136 S. Ct. 2056 (2016) (discovery of a valid outstanding warrant is an intervening development that can affect causation analysis)
- United States v. Kennedy, 638 F.3d 159 (3d Cir.) (no Fourth Amendment expectation of privacy for unauthorized sole occupants of rental vehicles)