U.S. v. Miranda-Sotolongo

Federal 7th Circuit Court
Criminal Court
Search and Seizure
Citation
Case Number: 
No. 14-2753
Decision Date: 
June 28, 2016
Federal District: 
C.D. Ill.
Holding: 
Affirmed and vacated in part and remanded

In prosecution on unlawful possession of firearm charge, Dist. Ct. did not err in denying defendant’s motion to suppress firearms seized during traffic stop, even though defendant argued that officer lacked reasonable suspicion to conduct traffic stop. Record showed that officer made stop after noting that defendant’s Indiana temporary tag registration looked odd because it was displayed where license plate normally went, and that check of relevant database did not contain number displayed on tag. As such, officer had reasonable suspicion to make stop, where officer reasonably believed that tag might be forgery designed to hide stolen vehicle. Fact that tag was properly displayed under Indiana law, or that absence of tag number in database could be explained by recent purchase of vehicle, did not require different result. Moreover, officer’s check of database did not constitute separate improper 4th Amendment search. Also, defendant failed to show that database used by officer to check tag registration was unreliable.