Summary
The United States Court of Appeals for the Eleventh Circuit held that a traffic stop based solely on an officer's mistake of law regarding an alleged inside rear-view-mirror requirement violated the Fourth Amendment. The court further held that the defendants' consent to search, given approximately three minutes after the unlawful stop, was tainted by the stop and did not purge the constitutional violation. The convictions were reversed.
Topics
Practice areas
Questions Presented
- Whether the traffic stop was supported by reasonable suspicion or probable cause when it was based on the officer's mistaken interpretation that the law required an inside rearview mirror.
- Whether Chanthasouxat's consent to search was sufficiently independent of the unlawful stop to purge the taint of the constitutional violation.
- Whether Chanthasouxat's statements to Xayasane while detained in the patrol car were fruits of the unlawful stop.
- Whether the traffic stop exceeded permissible limits in scope and duration.
Holdings
- An officer's mistake of law, no matter how reasonable or understandable, cannot provide the objectively reasonable grounds for reasonable suspicion or probable cause necessary to justify a traffic stop.
- Consent obtained approximately three minutes after an unlawful stop, without intervening circumstances, was a product of the unlawful stop and did not purge the taint.
- Chanthasouxat's statements to Xayasane while detained in the patrol car were fruits of the unlawful stop and had to be suppressed.
Key quotations
“And to that question we join the Fifth and Ninth Circuits in holding that a mistake of law cannot provide reasonable suspicion or probable cause to justify a traffic stop.” (¶ 41)
“We also agree with the Fifth Circuit, Lopez-Valdez, 178 F.3d at 289, and the Ninth Circuit, Lopez-Soto, 205 F.3d at 1106, that the good faith exception to the exclusionary rule established by United States v. Leon, 468 U.S. 897, 104 S.Ct. 3405, 82 L.Ed. 2d 677 (1984) should not be extended to excuse a vehicular search based on an officer's mistake of law.” (¶ 42)
“Accordingly, we reverse the Defendants' convictions and remand this case for further proceedings consistent with this opinion.” (¶ 53)
Factual background
Officer Phillip Carter stopped a van driven by Chanthasouxat because it lacked an inside rearview mirror, although the applicable Birmingham and Alabama laws did not require an inside mirror. After the stop, Carter questioned the occupants, obtained Chanthasouxat's consent to search, and officers found approximately fifteen kilograms of cocaine in the van. While detained in a patrol car, Chanthasouxat and Xayasane discussed how to reconcile their stories, and the conversation indicated that they knew they were carrying cocaine.
Procedural history
The United States District Court for the Northern District of Alabama denied defendants' motions to suppress drug evidence and statements arising from a traffic stop and subsequent detention. Defendants entered conditional guilty pleas and were each sentenced to concurrent sixty-month terms of imprisonment. The Eleventh Circuit reversed the convictions and remanded for further proceedings.
Remand instructions
The case was remanded for further proceedings consistent with the opinion after suppression of the drug evidence and Chanthasouxat's statements made in the back of the patrol car.