6th U.S. Circuit Court Finds Probable Cause for Traffic Stop

The traffic stop and subsequent search of defendant-Collazo’s van did not violate his Fourth Amendment rights because the officer had probable cause to stop the van for following too closely behind another vehicle. Further, the officers did not unconstitutionally prolong the stop, and they had probable cause for the search.Collazo challenged the traffic stop and sought to suppress the drug evidence seized.

When determining the legality of the traffic stop, the court applied the “stricter probable-cause standard” rather the “reasonable suspicion” standard, noting the need for “greater clarity in this circuit” on “the dividing line between when probable cause is required for a traffic stop and when reasonable suspicion is sufficient . . . .” The court determined that Collazo had violated a misdemeanor vehicle statute before he was pulled over. It also rejected his claim that “21 minutes was an unreasonable amount of time to complete the traffic stop and issue a warning for following too closely.” Collazo’s detainment beyond the 21 minutes was also justified because during that period, another officer had “developed a reasonable suspicion of criminal activity” based on his conversations with Collazo’s passenger, Cinthia. Her “admission that she had paid a relative to obtain prescription drugs [wa]s more than sufficient to establish a reasonable suspicion of criminal activity.”

The officers had probable cause for the warrantless search of Collazo’s van based on Cinthia’s demeanor, her admission that “her purse contained something illegal,” and the discovery of Suboxone strips in her purse that she obtained illegally. Also, the “Collazos’ conflicting stories regarding whether they were on their way to visit Cinthia’s sick father at an (unknown) hospital or at an (unknown) residence” and indications that Cinthia may have been “under the influence of a stimulant,” supported a finding of probable cause. The district court did not err by declining to address whether the Collazos consented to the search of the van where the issue was not dispositive—“the search of the van was justified by probable cause.”

The court affirmed the district court’s denial of the motion to suppress.