Reasonable Suspicion and 4th Amendment Law in U.S. v. Arvizu, 534 U.S. 266 (2001)
Title and Citation: U.S. v. Arvizu, 534 U.S. 266 (2001)
Type of Action: Review by the U.S. Supreme Court of a ruling made by the U.S. Court of Appeals for the Ninth Circuit, which held that evidence should be suppressed as a result of a violation of the Fourth Amendment right to privacy and protection from unwarranted and unreasonable search and seizure. The federal government sought to overturn the motion to suppress that was upheld by the Ninth Circuit.
Facts of the Case: On a January afternoon in 1998 Border Patrol agent Clinton Stoddard was manning a checkpoint on U.S. Highway 191, located north of Douglas, Arizona. At approximately 2:15 P.M. A motion sensor was tripped and Stoddard was notified that a vehicle was traversing an infrequently travelled road -- evidence used by Border Patrol agents to detect possible cases of drug or human smuggling from the nearby American/Mexican border. Despite this occurring at the time agents were supposed switch shifts, Stoddard elected to investigate further.
After reaching the vehicle which tripped the sensor, Stoddard discovered it to be a minivan -- yet another indicator of smuggling activity. According to Stoddard's report, the minivan's driver -- Ralph Arvizu -- began acting suspiciously when he saw Stoddard approach, averting eye contact...
A number of other visual cues suggested to Stoddard that Arvizu was engaged in criminal activity, including children sitting in the backseat with their knees elevated, as if something large and bulky was concealed in the area beneath their seats, and the children's peculiar waving -- which Stoddard believed to be the product of "coaching" by Arvizu.
Finally, a check of Arvizu's vehicle registration showed it to be registered to an address in Douglas which was widely known to authorities as a haven of illicit activity and drug sales. Based on this combination of evidentiary factors Stoddard asked for permission to search the vehicle, ultimately discovering nearly 119 pounds of
marijuana concealed within the vehicle.
Arvizu was charged with possession of marijuana with intent to distribute in district court, and in
federal court he petitioned to suppress the marijuana as evidence. Arvizu's argument held that Stoddard lacked the reasonable suspicion he needed by virtue of the Fourth Amendment to initiate a traffic stop. Citing the multitude of evidentiary facts provided by Stoddard, as well as the unnecessarily circuitous route Arvizu was driving from Douglas to Tucson, the district court denied Arvizu's motion to suppress the marijuana as evidence.
Arvizu then brought his appeal to the Ninth Circuit, which analyzed each of the 10 factors used by the district court in its ruling on an isolated basis. In doing so, the Ninth Circuit ruled that seven of the 10 factors were suggestive of justifiable explanation, and thus had little to no bearing on the reasonable-suspicion examination. According to the Ninth…
