Summary
This Eighth Circuit per curiam opinion affirms the district court's denial of a defendant's motion to suppress evidence seized during a traffic stop. The court held that the state trooper had reasonable suspicion to stop the vehicle after observing it cross the center line on a straight interstate, and probable cause to search based on the odor of marijuana. Relying on de novo and clear error standards of review, the appellate court found no constitutional violation under the Fourth Amendment.
Topics
Practice areas
Questions Presented
- Whether the traffic stop was supported by reasonable suspicion/probable cause under Nebraska law.
- Whether the vehicle search was supported by probable cause based on the odor of marijuana.
Holdings
- The officer had sufficient reasonable suspicion to stop the vehicle; an objectively reasonable belief that a traffic violation occurred satisfies the requirement even if the officer is mistaken about the law.
- The odor of marijuana provided probable cause to search the vehicle; the district court's finding was not clearly erroneous.
Key quotations
“An officer’s objectively reasonable belief that a traffic violation has occurred is sufficient to establish reasonable suspicion for a traffic stop even if the officer is mistaken about the law.” (at 1)
Factual background
A state trooper stopped Singleton on Interstate 80 after observing him briefly cross the center line. The trooper smelled marijuana emanating from the vehicle and searched it, seizing marijuana, a handgun, and other narcotics.
Procedural history
The district court denied Singleton's motion to suppress evidence seized during a traffic stop, finding probable cause for both the stop and the vehicle search. Singleton appealed, arguing lack of probable cause for the stop and the search.