U.S. v. Chagoya-Morales

Federal 7th Circuit Court
Criminal Court
Search and Seizure
Citation
Case Number: 
No. 16-1198
Decision Date: 
June 9, 2017
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

In prosecution on charge of illegal reentry into U.S. after having been deported, Dist. Ct. did not err in denying defendant’s motion to suppress information related to his identity/illegal status, where said information was discovered during traffic stop of vehicle in which defendant was passenger. While defendant argued that said information should have been suppressed because police lacked probable cause to stop said vehicle, Ct. found that defendant’s identity evidence was admissible even if evidence surrounding traffic stop was suppressed, since govt. sought only to use defendant’s identity from traffic stop, which could be learned outside context of traffic stop. Moreover, were defendant to be released, police immediately had probable cause to arrest him based on their knowledge of his identity and immigration status. Ct. also found that defendant’s prior aggravated robbery conviction supported Dist. Ct.’s imposition of 16-level enhancement under section 2L1.2(b)(1)(A)(ii) of USSG for purposes of sentencing defendant to 48-month term of incarceration.