United States v. Webster
2010 U.S. App. LEXIS 23127
| 8th Cir. | 2010Background
- Webster was arrested following a third controlled crack cocaine purchase arranged by a confidential informant.
- Informant previously completed two controlled buys from Webster, known to informant as 'Harold Smith.'
- On the third meeting, officers used a signal-based approach; Webster briefly interacted with the informant near a Family Dollar in Des Moines and attempted to drive away, ramming a patrol car.
- A warrantless search of Webster's truck yielded crack cocaine, marijuana, and paraphernalia; Webster admitted involvement in drug dealing after Miranda warnings.
- Federal indictment added a conspiracy count; state charges in Iowa were dismissed as federal charges proceeded, and evidence was later purged under a routine biannual destruction policy.
- Webster challenged both the suppression of evidence and the dismissal due to destruction of evidence; the district court denied relief, and Webster was ultimately convicted on the conspiracy count.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for warrantless arrest and search | Webster argues lack of probable cause based on informant reliability and misidentification. | Webster contends informant information insufficient for probable cause and arrest basis disputed. | Probable cause supported; arrest and subsequent search upheld. |
| Validity of the vehicle search under Gant and automobile exception | Webster asserts no basis for search incident to arrest given handcuffed state. | Webster's arrest and the automobile exception justified search despite Gant nuances. | Search justified under automobile exception; evidence seizure upheld. |
| Destruction of evidence and due process | Webster argues destruction violated due process and could be exculpatory. | State acted in good faith (negligence at most); destruction not bad faith, exculatory value unlikely. | No bad faith; no due process violation; dismissal denied. |
Key Cases Cited
- United States v. Parish, 606 F.3d 480 (8th Cir. 2010) (probable cause considers trustworthy informant information)
- United States v. Henderson, 613 F.3d 1177 (8th Cir. 2010) (latitude in interpreting facts for probable cause)
- United States v. Mendoza, 421 F.3d 663 (8th Cir. 2005) (probable cause need not be certainty)
- United States v. Jones, 535 F.3d 886 (8th Cir. 2008) (probable cause suffices for probable criminal activity)
- United States v. Morrison, 594 F.3d 626 (8th Cir. 2010) (reliability of informants with track record)
- United States v. Neal, 528 F.3d 1069 (8th Cir. 2008) (informant reliability and corroboration)
- Brown v. United States, 49 F.3d 1346 (8th Cir. 1995) (informant's track record supports reliability)
- United States v. Gates, 462 U.S. 213 (1983) (reliability of informants and totality of circumstances)
- Trombetta v. Illinois, 467 U.S. 479 (1984) (no due process violation absent exculpatory value of destroyed evidence)
- Youngblood v. State of Arizona, 488 U.S. 51 (1988) (bad faith required for destruction of evidence claim)
- United States v. Williams, 577 F.3d 878 (8th Cir. 2009) (due process standard for destruction of evidence and bad faith)
- United States v. Belton, 453 U.S. 454 (1981) (automatic automobile search incident to arrest framework)
- United States v. Gant, 556 U.S. 335 (U.S. 2009) (limits on vehicle search incident to arrest; supports automobile exception)