Summary
The Vermont Supreme Court affirmed the denial of Eric K. Manning’s motion to suppress evidence and statements obtained during a traffic-stop investigation. The court held that Manning was seized when he exited his vehicle, but that the officer had reasonable suspicion to expand the suspended-license investigation into a drug investigation. The court also addressed Manning’s claim that questioning before Miranda warnings constituted custodial interrogation.
Topics
Practice areas
Questions Presented
- Whether defendant was seized when the officer asked or ordered him to exit the vehicle.
- Whether the officer had reasonable suspicion to expand the suspended-license investigation into an investigation of possible drug possession and to question defendant about the prescription bottle.
- Whether defendant's consent to the seizure and search of the prescription bottle was tainted by an unlawful seizure.
- Whether defendant was subjected to custodial interrogation without Miranda warnings before the officer opened the bottle and arrested him.
Holdings
- Defendant was seized when he exited the vehicle, but the seizure and the subsequent questioning about the prescription bottle were lawful because the officer had reasonable suspicion, based on the totality of the circumstances, that defendant possessed illegal drugs.
- Defendant's consent was not tainted because the officer's seizure and expansion of the investigation were lawful.
- Defendant was not in custody when questioned before the bottle was opened and was therefore not entitled to Miranda warnings at that time.
Key quotations
“While we agree with defendant, rather than with the trial court, that he was seized upon exiting the vehicle, we believe that the officer had reasonable suspicion for the exit order and subsequent questioning about the prescription bottle.” (¶ 9)
“Looking at the circumstances as a whole, particularly through the lens of the officer’s experience in law enforcement, the officer had reasonable suspicion to believe that defendant was in possession of illegal drugs.” (¶ 16)
“We therefore conclude that, based on the totality of the circumstances, defendant was not in custody and was not entitled to Miranda warnings.” (¶ 28)
Factual background
A police officer encountered defendant sitting in a vehicle parked in an area of a supermarket lot known for drug activity and learned that the vehicle's registered owner's license was suspended. As the officer approached, defendant appeared to conceal an object, later identified as a prescription bottle with a worn label; defendant was nervous, shaking, and carrying a large amount of crumpled cash. The officer questioned defendant, obtained permission to open the bottle, and found cocaine. Defendant was later arrested, additional cocaine and pills were discovered, and he received Miranda warnings at the police station.
Procedural history
The Superior Court, Rutland Unit, Criminal Division denied defendant's motion to suppress and dismiss in a written order dated May 27, 2014. The court concluded that the encounter was consensual and that defendant was not in custody for Miranda purposes. On appeal, the Vermont Supreme Court agreed that suppression was properly denied, but affirmed on the separate ground that defendant was seized when ordered out of the vehicle and that the officer had reasonable suspicion for the expanded investigation.