Sunday, November 3, 2013

United States v. Arvizu case brief

United States v. Arvizu case brief summary
534 U.S. 266 (2002)

Defendant was charged with a drug offense and asserted that the investigatory stop during which drugs were found in his vehicle was unlawful. Upon the grant of a writ of certiorari, petitioner United States appealed the judgment of the United States Court of Appeals for the Ninth Circuit, which reversed the district court's denial of defendant's motion to suppress drug evidence obtained during the stop.

Defendant, traveling with a woman and children in a minivan, was stopped by an agent on an unpaved and rarely traveled road near the United States border which was commonly used by smugglers to avoid a border patrol checkpoint. The agent determined that the unusual behavior of the occupants justified an investigatory stop, during which the agent discovered a substantial amount of drugs. The appellate court found that certain of the suspicious circumstances, evaluated in isolation, were susceptible to innocent explanations and thus insufficient to support a finding of reasonable suspicion of criminal activity to justify the investigatory stop.

  • The United States Supreme Court held, however, that suppression of the drug evidence was not required, since the totality of the circumstances warranted the stop for further investigation of defendant's vehicle, regardless of whether the facts taken in isolation appeared innocent. 
  • It was reasonable for the agent to make commonsense inferences from his observations and his experience that defendant was attempting to avoid the checkpoint, rather than taking his family on a recreational outing.


The judgment reversing the denial of defendant's motion to suppress was reversed, and the case was remanded.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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