Miguel Correa was facing years in prison after he was recently arrested and indicted for possession with intent to distribute over 500 grams of methamphetamine. The lower court, however, suppressed the evidence seized reasoning that Correa was illegally detained and searched in violation of the Fourth Amendment to the U.S. Constitution.
However, after reviewing the case, U.S. v Miguel Correa, the U.S. Court of Appeals for the Eighth Circuit reversed the lower courts suppression order.
The Facts
In April of this year, a bus traveling carrying several passengers, including Correa, was traveling from Las Vegas, Nevada, to Des Moines, Iowa.
The bus stopped in Omaha where state troopers inspected the passenger list for individuals who had purchased their bus tickets with cash the day before, as this is commonly an indicator of drug trafficking.
Troopers found that Correa had done so, and began to question him while on the bus. In the course of asking Correa about the details of his trip, they asked to search his bag, and he consented. Court records indicate that Correa stood up as if he anticipated an investigative pat down, and also offered his jacket to be searched. One trooper found two duct-taped wet wipe packages in Correa's jacket that he suspected contained methamphetamines. Correa was then handcuffed and escorted from the bus. Soon after, authorities found over 500 grams of methamphetamines in the wet packages.
Correa was charged with possession with intent to distribute a controlled substance under federal law 21 U.S.C. 841. His attorney moved to suppress his statements and evidence arguing that the troopers' initial questioning on the bus was an improper detention since it was not supported by a reasonable suspicion that a crime had been committed, and that no probable cause existed for the subsequent arrest. As such, the contraband was illegally obtained.
Fourth Amendment Protections against Unreasonable Search and Seizures
The Fourth Amendment to the U.S. Constitution guarantees freedom from unreasonable searches and seizures. Law enforcement must have a reasonable suspicion of criminal activity before stopping and searching a person. This principle is a cornerstone of our criminal justice system, and all evidence obtained in violation of the Fourth Amendment is inadmissible in court.
The Eight Circuit Court of Appeals Reverses
The trial court agreed with Correa that his contraband was illegally seized and granted Correa's motion to suppress. Prosecutors appealed to the Eighth Circuit, arguing that the troopers' conversation with Correa did not constitute a detention that would warrant protection of unreasonable search and seizure under the Fourth Amendment. It relied on U.S. v. Drayton, a Supreme Court case with similar facts. In Drayton, a bus passenger was asked benign questions by authorities before they asked to search the passenger's luggage for drugs. The Court in Drayton held that the questioning did not amount to a detention because
"[t]here was no application of force, no intimidating movement, no overwhelming show of force, no brandishing of weapons, no blocking of exits, no threat, no command, not even an authoritative tone of voice."
The Eighth Circuit in U.S. v Miguel Correa thought the prosecutor's argument was convincing and thereby remanded the case for further proceedings.
Correa is a stark reminder that the protections afforded to defendants are not black and white. Correa faces years in prison if convicted. For now, his future hangs in limbo while the lower court reconsiders the case.
