United States v. Motley
344 F.App'x 445 (2009)
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Rule of Law:
Prolonging a traffic stop beyond the time reasonably required to complete its initial mission constitutes an unlawful seizure under the Fourth Amendment, unless officers possess reasonable suspicion of other criminal activity. When such suspicion is based on an informant's tip, the tip must be deemed reliable under the totality of the circumstances, and a tip with low reliability requires significant independent police corroboration to justify the extended detention.
Facts:
- Detective Ames received a tip from an unnamed relative of a confidential informant that Myron Motley was dealing cocaine.
- The tip stated Motley lived at Harrah's casino, drove a specific car, and would transform powder cocaine into crack for distribution to middlemen.
- Ames's investigation revealed that Motley was a high-stakes gambler at Harrah's with no listed employer, had an associate arrested for selling crack cocaine at the casino, made phone calls the staff found suspicious, and was involved in an incident where his room safe was broken into after he reported losing the key.
- Believing he lacked probable cause, Ames asked Trooper Manion to conduct a traffic stop on Motley's vehicle and develop independent probable cause.
- Trooper Manion initiated a traffic stop of Motley's vehicle.
- Manion detained Motley for approximately fifty minutes; the first fifteen to twenty minutes were related to the traffic stop, and the remaining thirty minutes were spent waiting for a narcotics-detection dog to arrive.
- During the traffic stop portion of the detention, Manion did not discover any independent evidence of illicit narcotics activity.
Procedural Posture:
- Myron Motley was charged in federal district court with possession with intent to distribute cocaine base and cocaine.
- Motley filed a motion to suppress the evidence seized from his vehicle, arguing the stop and subsequent detention were unconstitutional.
- The district court denied the motion to suppress.
- Motley entered a conditional guilty plea, preserving his right to appeal the district court's denial of his suppression motion.
- Motley (appellant) appealed his convictions to the U.S. Court of Appeals for the Ninth Circuit.
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Issue:
Does extending a traffic stop for thirty minutes to await the arrival of a narcotics-detection dog violate the Fourth Amendment when the detaining officer's suspicion is based on information from another detective, whose own suspicion stems from an uncorroborated tip from an informant of unproven reliability?
Opinions:
Majority - Per Curiam
Yes. The thirty-minute extension of the traffic stop to await a narcotics dog constituted an unlawful seizure because it was not supported by reasonable suspicion. The court reasoned that the legality of the extended detention depended on whether Detective Ames had reasonable suspicion that could be imputed to Trooper Manion under the collective knowledge doctrine. Applying the totality-of-the-circumstances test from Illinois v. Gates, the court found the informant's tip had a very low degree of reliability. The tipster was effectively anonymous, had no history of reliability, provided no basis of knowledge, and offered no predictive information about Motley's future actions that was corroborated by police. The additional information gathered from Harrah's was insufficient to bolster the weak tip to the level of reasonable suspicion, amounting to nothing more than an 'inchoate and unparticularized suspicion' or a hunch.
Dissenting - Chief Judge Kozinski
No. The detention did not violate the Fourth Amendment because the police had the 'minimal level of objective justification' required for reasonable suspicion. The majority applied an overly demanding standard, ignoring that reasonable suspicion is less stringent than probable cause. The dissent argued that the information from the Harrah's security director was highly credible, as the casino had an incentive not to falsely incriminate a high-rolling patron. This credible information from the hotel, combined with the informant's tip—even if assigned minimal weight—was more than sufficient to establish reasonable suspicion, comparable to the facts in landmark cases like Terry v. Ohio and United States v. Sokolow.
Analysis:
This decision reaffirms the principle that the duration of a traffic stop must be tethered to its original purpose unless new, particularized suspicion arises. It emphasizes that under the collective knowledge doctrine, the imputed suspicion must actually meet the constitutional standard at its source. The case provides a clear application of the informant reliability test, demonstrating that a collection of otherwise suspicious but uncorroborated details cannot salvage a fundamentally unreliable tip to justify a Fourth Amendment seizure. This holding serves as a check on law enforcement's ability to use pretextual traffic stops as a basis for prolonged 'fishing expeditions' for evidence of unrelated crimes without sufficient cause.
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