Federal 7th Circuit Court
Criminal Court
Search and Seizure
In prosecution on drug conspiracy charge, Dist. Ct. did not err in denying defendant's motion to suppress drugs seized from defendant's car after defendant's car was stopped for traffic offense. While defendant argued that seizure was illegal since he did not actually commit lane violation, Dist. Ct. could properly credit testimony of arresting officer as to existence of traffic violation. Moreover, collective knowledge of law enforcement was sufficient to supply probable cause to arrest defendant for drug offense even though arresting officer may not have known of previous controlled drug purchase involving defendant. Also, officers could properly search defendant's vehicle following his stop on traffic violation since law enforcement could properly have believed that vehicle contained evidence of criminal activity where they had kept defendant under surveillance on day of arrest and had seen defendant accept $5,000 drug payment. Fact that arresting officer relied on other justification to conduct search of vehicle is irrelevant.