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United States v. Huebner, Andrew L.

Citation: Not availableDocket: 02-3504

Court: Court of Appeals for the Seventh Circuit; February 1, 2004; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves the appeal of a defendant, Huebner, who was arrested and charged with possession with intent to distribute cocaine under 21 U.S.C. § 841. Following a traffic stop and subsequent searches, law enforcement discovered significant quantities of drugs and cash in Huebner's possession. Huebner challenged the arrest and search, arguing a lack of probable cause and violations of his Fourth Amendment rights. His arrest was based on information from a confidential informant, who detailed Huebner's drug activities, which were corroborated by independent police investigations and surveillance. The district court denied Huebner's motion to suppress the evidence, finding the informant credible and the officers' testimonies consistent, despite minor discrepancies. Huebner entered a conditional guilty plea while preserving the right to appeal the suppression ruling. On appeal, the appellate court upheld the district court's decision, affirming the officers' credibility and the sufficiency of probable cause. The court emphasized the reliability of the informant's information and the corroborative nature of the evidence, concluding that the law enforcement actions were justified under the circumstances presented.

Legal Issues Addressed

Credibility of Law Enforcement Testimony

Application: The district court deemed the officers' testimony credible despite minor inconsistencies, which did not undermine the probable cause determination.

Reasoning: The appellate review respects the district court’s credibility findings unless they lack foundation. The court affirmed the denial based on the officers’ consistent testimony regarding the drug transaction and corroborated background information.

Fourth Amendment Rights and Motion to Suppress

Application: Huebner's motion to suppress evidence based on alleged Fourth Amendment violations was denied due to sufficient probable cause for warrantless actions.

Reasoning: The district court found sufficient probable cause for a warrantless stop and search, thus denying Huebner’s motion to suppress.

Informant Reliability and Corroboration

Application: The court upheld the informant's reliability due to the detailed information provided and corroboration through independent police investigation.

Reasoning: Cardella's information was corroborated through independent police investigation and aligned with tips from other informants about Huebner's drug dealings.

Probable Cause for Arrest and Search

Application: The court found that the totality of circumstances, including corroborated informant information and surveillance, provided sufficient probable cause for Huebner's arrest and vehicle search.

Reasoning: The totality of circumstances indicated that Huebner's activities warranted a reasonable belief that a narcotics crime was imminent.