The Ninth Circuit Court of Appeals has reversed a lower court’s decision to suppress evidence seized from a man’s car following a traffic stop in Nevada. The case, *United States of America v. Triston Harris Steinman*, centered on whether a state trooper violated Steinman’s Fourth Amendment rights during the stop. The Appeals Court found that the trooper acted appropriately and that the evidence, including firearms and ammunition, should not have been excluded.
The original traffic stop occurred on August 12, 2022, when Nevada State Trooper William Boyer clocked Steinman driving a gray BMW at 89 miles per hour, exceeding the speed limit. The trooper initiated a traffic stop. During the stop, the trooper observed an ammunition box and items covered by a blanket in the vehicle. Steinman admitted to having ammunition but denied having any guns.
The district court, where the case was initially heard, ruled that the trooper had violated Steinman’s Fourth Amendment rights in several ways, including by prolonging the traffic stop without sufficient justification, lacking probable cause to seize the vehicle, and obtaining an overbroad search warrant. Based on these findings, the district court suppressed the evidence found in the car.
The Ninth Circuit, however, disagreed with the district court’s conclusions, leading to the reversal.
Was the Traffic Stop Unconstitutionally Prolonged?
The Appeals Court addressed the central question of whether the traffic stop was unlawfully extended. The court noted that a traffic stop is a temporary detention, and its scope is limited to addressing the traffic violation, making related inquiries, and ensuring safety. A stop can become unlawful if it’s extended beyond the time needed to address the traffic infraction.
Key Findings:
* Initial Actions Lawful: The court found that the trooper’s initial actions, including asking Steinman to exit the car and requesting a criminal history check, were either within the scope of a legitimate traffic stop or did not unduly prolong it. The court stated that the trooper was justified in asking Steinman to step out of the car for officer safety.
* Criminal History Check Justified: The court determined that running a criminal history check was a “negligibly burdensome precaution” for officer safety and did not violate the Fourth Amendment.
* Reasonable Suspicion: The court held that after the trooper learned of Steinman’s felony conviction, he had reasonable suspicion to believe Steinman was engaged in criminal activity, specifically the possession of firearms in violation of Nevada law. This reasonable suspicion justified any further extension of the stop.
Did the Trooper Have Probable Cause to Seize the BMW?
The Appeals Court also overturned the lower court’s finding that the trooper lacked probable cause to seize Steinman’s BMW. The court explained that the “automobile exception” to the Fourth Amendment allows for a warrantless search of a vehicle if there’s probable cause to believe it contains evidence of a crime.
Key Findings:
* Probable Cause for State Law Violation: The court found that the totality of the circumstances, including the ammunition box in plain view, the blanket covering items, evasive answers from Steinman, and his felony conviction, provided the trooper with probable cause to believe that the vehicle contained firearms, a violation of Nevada law.
* Probable Cause for Federal Law Violation: The Appeals Court also concluded that the trooper had probable cause to believe Steinman possessed ammunition as a felon, violating federal law.
Cross-Enforcement and Federal Law
This part of the ruling is particularly significant. The court addressed the question of “cross-enforcement,” meaning whether a state officer can consider violations of federal law when justifying a search and seizure. The court generally agreed that state officers may consider federal law violations, as part of the circumstances, in justifying a search and seizure.
The court reasoned that the Supremacy Clause of the U.S. Constitution makes federal law supreme, and the state of Nevada has an interest in ensuring that federal laws, like the prohibition on felons possessing ammunition, are enforced. The court also noted that the Fourth Amendment is a federal standard, and state law does not alter its content.
Judge George H. Wu, a Senior District Judge sitting by designation, concurred with the majority opinion but disagreed with Part II.B.2, which addressed the “cross-enforcement” issue. Judge Wu argued that the court shouldn’t have addressed this issue because it was not necessary to the case’s outcome and could have broad implications.
Warrant Overbreadth
Finally, the court addressed the district court’s finding that the search warrant was overbroad. The Appeals Court accepted that the warrant was overbroad but determined that it didn’t require the suppression of the evidence.
Key Findings:
* Automobile Exception Applies: The court held that because the trooper had probable cause to search the BMW under the automobile exception, the overbreadth of the warrant was immaterial. The court cited precedent that states evidence seized during a search with a defective warrant can still be admissible if the search was otherwise lawful under an exception to the warrant requirement.
The Ruling
In summary, the Ninth Circuit Court of Appeals reversed the district court’s decision. The court found that the traffic stop was not unconstitutionally prolonged, the seizure of the vehicle was supported by probable cause, and the overbreadth of the warrant did not require suppression of the evidence. As a result, the guns and ammunition seized from Steinman’s vehicle are admissible in court.