Searching over 5,500,000 cases.

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

United States v. Woods

United States District Court, N.D. Alabama, Southern Division

March 26, 2019




         Defendant Mustafaa Woods challenges the constitutionality of the search of a rental vehicle that he was operating. The search occurred incident to a traffic stop and produced a firearm, for which Mr. Woods has been charged under 18 U.S.C. § 922(g)(1). (Doc. 1).

         Mr. Woods asserts his constitutional challenge on the basis of the Fourth Amendment of the United States Constitution. (Doc. 16, p. 1). At the suppression hearing in this case, counsel for Mr. Woods conceded that following the traffic stop, a search of the vehicle was inevitable for many reasons, among them the fact that a representative of the rental company was coming to retrieve the vehicle and could have given consent to search. Counsel for Mr. Woods explained that Mr. Woods primarily challenges the validity of the stop that led to the vehicle search. Mr. Woods contends that the arresting officer did not have a legitimate basis for the stop and that the officer used a ruse to justify the stop. (Doc. 25, pp. 3-4, 42-44).

         The Fourth Amendment prohibits “unreasonable searches and seizures.” U.S. Const. amend. IV. “As a general matter, the decision to stop an automobile is reasonable where the police have probable cause to believe that a traffic violation has occurred.” Whren v. U.S., 517 U.S. 806, 810 (1996). In his suppression motion, Mr. Woods asks whether a law enforcement officer who wants to question an individual can look for a reason to stop the vehicle in which the individual is travelling, and, if so, how far an officer may go in looking for an opportunity to initiate a stop.

         On the day of the incident in question, a Jefferson County sheriff's deputy was investigating a stolen vehicle case when he observed Mr. Woods driving through the parking lot of a motel in a vehicle bearing California plates. (Doc. 26, pp. 6-9, 17-18).0F[1] Based on previous meetings, the deputy and Mr. Woods knew one another. (Doc. 26, pp. 8, 12, 27). The deputy knew that detectives in the Sheriff's Office had wanted to talk to Mr. Woods about a recent shooting in Jefferson County (unrelated to the stolen vehicle case), so the deputy decided to “conduct an investigatory stop on Mr. Woods.” (Doc. 26, p. 9; see also Doc. 26, p.19). The deputy stated that he planned to stop Mr. Woods and then contact the detectives to ask if they wanted to speak to Mr. Woods. (Doc. 26, p. 19). When Mr. Woods drove out of the motel parking lot, the deputy left as well and followed Mr. Woods to the interstate. (Doc. 26, p. 9). The deputy testified that up to the point at which he followed Mr. Woods onto the interstate, some two or three blocks from the motel, he did not have a reason to pull Mr. Woods over. (Doc. 26, pp. 19, 22).

         The deputy testified that on the interstate, over the course of a mile or two, Mr. Woods committed three infractions of the driving code by changing lanes without signaling, driving above the speed limit, and following other vehicles too closely. (Doc. 26, pp. 10-11). When Mr. Woods exited the interstate, the deputy followed him and initiated his lights. Mr. Woods pulled over. (Doc. 26, pp. 11, 24-25).

         During his initial conversation with Mr. Woods, the deputy learned that the vehicle was a rental. (Doc. 26, p. 31). The deputy testified that while he was speaking with Mr. Woods, he detected the odor of marijuana coming from the vehicle. (Doc. 26, pp. 12, 29-30). After obtaining identification from Mr. Woods and his passenger, the deputy returned to his car to check for outstanding warrants, call for backup, and write a warning. (Doc. 26, pp. 13-15, 25, 33). While the deputy was in his patrol car, he contacted the rental company to ask questions about the rental vehicle. (Doc. 26, pp. 35, 38). A manager at the rental company stated that Mr. Woods was not an authorized operator of the vehicle and that she would send a representative to get the vehicle. (Doc. 26, pp. 35-36, 38). From that point forward, the deputy knew that he was not going to allow Mr. Woods to drive away from the stop. (Doc. 26, p. 38).

         After the deputy gave Mr. Woods the warning (for failing to signal and for following too closely but not for speeding), the deputy asked Mr. Woods if there was a firearm in the vehicle. Mr. Woods stated that there was a firearm in the console, so the deputy removed Mr. Woods and his passenger from the car and searched the vehicle. (Doc. 26. pp. 15-16). The deputy found two guns and drugs in the car. (Doc. 26, pp. 16-17). Mr. Woods's passenger claimed one of the guns and the drugs. (Doc. 26, p. 17). The gun in the console is attributed to Mr. Woods, but he contends that the gun belonged to his girlfriend. (Doc. 26, p. 15).

         There is no dashcam or bodycam footage of the stop. (Doc. 26, p. 23). The deputy did not tell Mr. Woods about the detectives who supposedly wanted to speak with him (Mr. Woods), and the deputy did not mention to Mr. Woods the odor of marijuana that the deputy supposedly detected when he first walked up to the car. (Doc. 26, pp. 29-30). The purported odor of marijuana is significant because the deputy testified that his detection of the scent of marijuana during his initial conversation with Mr. Woods gave him a basis for searching the vehicle. (Doc. 26, p. 31).1F[2]

         The United States contends that the deputy stopped Mr. Woods because Mr. Woods committed two traffic violations, and the deputy searched the rental vehicle because Mr. Woods admitted that there was a firearm in the vehicle. Mr. Woods argues that the deputy's testimony about the purported traffic violations is not credible and that the traffic stop was a pretense for an otherwise unauthorized stop. Both parties agree that “there is no valid reason for a police officer to [conduct a traffic] stop just because a detective wants to talk to somebody. There's absolutely no probable cause. There's no reasonable articulable suspicion whatsoever at that point.” (Doc. 26, p. 46); see also (Doc. 26, pp. 47-48) (“There's no legitimate reason to stop someone for an investigatory [traffic] stop. There's no such thing.”).

         Supreme Court precedent regarding the driving public establishes a wide berth for police action. See United States v. Knotts, 460 U.S. 276, 281 (1983) (“A person travelling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another.”). In United States v. Jones, 565 U.S. 400 (2012), the Supreme Court placed limits on Knotts in the context of GPS tracking, but the Supreme Court did not abrogate the general rule announced in Knotts. The Supreme Court explained:

This Court has to date not deviated from the understanding that mere visual observation does not constitute a search. . . . We accordingly held in Knotts that “[a] person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another.” . . . Thus, even assuming that the concurrence is correct to say that “[t]raditional surveillance” of Jones for a 4-week period “would have required a large team of agents, multiple vehicles, and perhaps aerial assistance, ” . . . our cases suggest that such visual observation is constitutionally permissible.

Jones, 565 U.S. at 412 (internal citations omitted).

         In the context of a Fourth Amendment challenge to a search and seizure, an officer's subjective reasons for conducting surveillance and a traffic stop are irrelevant. Whren, 517 U.S. at 813. In Whren, the Supreme Court held that reasonableness is an objective standard under the Fourth Amendment. Whren, 517 U.S. at 813-14. Consequently, the ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.