U.S. v. Reaves

In prosecution on drug distribution charge, Dist. Ct. did not err in denying defendant’s motion to suppress drugs seized from defendant’s vehicle in which defendant was passenger, where defendant’s vehicle had been subject of GPS device that had been planted by police, and where driver of defendant’s vehicle had been spotted making illegal lane change. Police had probable cause to stop defendant’s vehicle, where video confirmed that defendant’s vehicle had drifted into other lane, and instant search was permissible under automobile exception to 4th Amendment’s warrant requirement, since: (1) at time of instant stop, defendant was under investigation for trafficking narcotics; (2) police had obtained warrant to install GPS tracker after conducting controlled drug buys and obtaining information from informant; and (3) instant police had probable cause to believe defendant’s vehicle contained evidence of drug activity, where GPS’s tracking confirmed drug trafficking information supplied by informant.