U.S. v. Ruiz

In prosecution on drug distribution charge, Dist. Ct. did not err in denying defendant’s motion to suppress drugs found in two hidden compartments of defendant’s car, after: (1) police had initially stopped defendant, unsuccessfully searched his car for ten minutes, and waited additional 20 minutes for arrival of canine unit; and (2) when canine unit failed to arrive, defendant drove his car to police station and eventually showed police location of hidden compartments. Police had reasonable suspicion to stop defendant to investigate presence of drugs where: (1) police had previously observed defendant interacting with two individuals who were subject of ongoing drug-trafficking investigation; and (2) after said interaction, police observed defendant enter his car and engage in certain maneuvers indicating existence of trap compartments in his car. Moreover, length of time following initial stop to time of drug discovery did not transform initial stop into de facto arrest, where officers detained defendant for less than 20 minutes prior to defendant giving officers consent to search his car. Also, defendant’s encounter with officers was not custodial in nature so as to require immediate giving of Miranda warning, where encounter took place in public view and officers allowed defendant to drive his car to police station.