US v. Taylor

The standard of a Fourth Amendment analysis is reasonableness.

Following a traffic stop, Defendant was convicted of being a felon in possession of a firearm. Defendant appealed the district court’s denial of his motion to suppress evidence of the gun and statements made to police during the traffic stop. On appeal, Defendant claimed that the police violated his Fourth Amendment rights by prolonging the traffic stop to investigate non-traffic offenses and conducting an unconsented search; Defendant argued that those actions were “too attenuated from the traffic stop.” The Court reasoned that the district court’s denial of the motion to suppress was proper because of the totality of the circumstances (i.e. Defendant's previous convictions, lack of a license, and an empty fanny pack were sufficient for police to reasonably suspect that Defendant posed a threat to officer safety). Applying the same totality of circumstances principle to Defendant's consent to the search, the Court reasoned that Defendant's response to the officer’s request to search the car -- “it don’t matter to me” -- indicated voluntary consent. Because the officers did not violate Defendant's Fourth Amendment rights, the Court affirmed the district court’s denial of Defendant's motion to suppress and affirmed Defendant's conviction of being a felon in possession of a firearm. AFFIRMED.