United States v. Carlos Armando Sanchez

Citations: 861 F.2d 89; 1988 U.S. App. LEXIS 16140; 1988 WL 121249Docket: 88-1388

Court: Court of Appeals for the Fifth Circuit; November 16, 1988; Federal Appellate Court

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Carlos Armando Sanchez appeals a district court order denying his motion to suppress evidence obtained from a warrantless search of his automobile. The United States Court of Appeals for the Fifth Circuit affirms the lower court's decision, ruling that the search was not inconsistent with the Fourth Amendment. 

The case originated on October 14, 1987, when Agent Nardolillo from the Colorado Bureau of Investigation contacted Agent Villaruel of the DEA regarding Sanchez's involvement in illegal drug distribution. Sanchez had agreed to sell 58,000 units of the controlled substance Ionamin, and had a prior arrest for the unlawful sale of the drug. The next day, Nardolillo and Villaruel arranged a meeting with Sanchez in El Paso to negotiate a purchase of 100,000 units of Ionamin. During the meeting, Sanchez indicated he had brought the drug with him but became agitated, fled the scene, and was pursued and stopped by law enforcement just a few blocks away.

Upon stopping Sanchez, the agents removed him from his vehicle and, after ensuring the car was still running, searched the trunk, where they found two suitcases Sanchez had identified as containing Ionamin. The suitcases were opened, confirming the presence of the drug. A subsequent search of the vehicle yielded no additional contraband, but Sanchez later acknowledged having more Ionamin at his home, which he consented to have searched. This search revealed additional quantities of Ionamin.

Sanchez was indicted for possession with intent to distribute Ionamin, violating 21 U.S.C. § 841(a)(1). He filed a motion to suppress evidence obtained from the search of his suitcases and home, which the district court denied, citing the automobile exception to the warrant requirement. After this denial, Sanchez entered a conditional guilty plea, preserving his right to appeal, and was sentenced to three years in prison, with six months of confinement and the remainder suspended. In his appeal, Sanchez argues that the warrantless search of his suitcases in the trunk of his car violated the Fourth Amendment. The Government defends the search based on the automobile exception, which permits warrantless searches if law enforcement believes the vehicle contains illegal contraband. This exception originated from the Supreme Court's decision in Carroll v. United States, emphasizing the need for swift action to secure contraband in movable vehicles. However, subsequent rulings, such as United States v. Chadwick, limited this exception, ruling that warrantless searches of closed containers, even if in a vehicle, violate privacy expectations. In Chadwick, the Court found that a footlocker could not be searched without a warrant, affirming stronger privacy rights over personal luggage than those afforded to vehicles. Similarly, in Arkansas v. Sanders, the Court restricted the exception further, highlighting the need for a warrant to search closed containers regardless of their mobility if law enforcement's knowledge of their contents predates their placement in a vehicle.

Police officers followed a suspect's taxicab after he left the airport and stopped the vehicle several blocks away. They seized a suitcase from the trunk and conducted a warrantless search, finding marijuana. The Supreme Court in *Sanders* ruled that the automobile exception could not justify this warrantless search, even though the officers had probable cause before the suitcase was placed in the taxi's trunk. The Court distinguished this case from *Ross*, which allowed warrantless searches of vehicles based on probable cause regarding the object of the search, regardless of the container's nature. In *Ross*, the Court held that the scope of such searches is determined by probable cause regarding the vehicle's contents rather than the containers themselves. Subsequently, in *Johns*, the Supreme Court upheld a warrantless search of packages found in a truck three days after their seizure, reaffirming the automobile exception's broad applicability. It emphasized that if probable cause justifies searching a lawfully stopped vehicle, it extends to all parts of the vehicle and its contents that may conceal contraband. This interpretation has been followed in subsequent cases within the Circuit.

The case involves the application of the automobile exception to the Fourth Amendment's warrant requirement, evaluating whether the warrantless search of burgundy suitcases in Sanchez's vehicle was justified. The court finds that the situation aligns more closely with precedent set in Ross rather than Sanders. Drug agents initially focused on the suitcases but had probable cause to believe both the vehicle and the suitcases contained contraband (Ionamin). The agents' lack of prior knowledge regarding the suitcases' contents does not negate their probable cause to search the vehicle itself. Consequently, the warrantless search was deemed constitutional under the automobile exception, affirming the district court's denial of Sanchez's motion to suppress. After the search, Sanchez admitted to having more Ionamin at his home, leading agents to obtain his consent to search the residence, where additional contraband was discovered. Sanchez was ultimately indicted for possession with intent to distribute Ionamin and entered a conditional guilty plea, reserving the right to appeal the suppression denial. The district court sentenced him to three years in prison, with part of the term suspended.

Sanchez argues that the warrantless search of two burgundy suitcases in his car's trunk violated the Fourth Amendment. The Government defends the search by citing the automobile exception, which allows warrantless searches when law enforcement believes a vehicle contains illegally transported contraband, as established in Carroll v. United States. This exception arose from the need for swift action by law enforcement regarding movable contraband. However, subsequent Supreme Court rulings have limited this exception. In United States v. Chadwick, the Court found unconstitutional the warrantless search of a footlocker in a trunk, emphasizing that a person’s expectation of privacy in personal luggage is greater than in a vehicle. Similarly, in Arkansas v. Sanders, the Court again restricted the automobile exception by ruling against the warrantless search of a suitcase in a moving taxicab, reinforcing that personal luggage remains protected even when transported in a vehicle.

In Sanders, police had probable cause to search a suitcase before it was placed in a taxicab's trunk, but not to search the entire vehicle, meaning the automobile exception from Carroll was inapplicable. Following the Supreme Court's decisions in Chadwick and Sanders, there was an initial resistance to broadly interpreting the automobile exception. However, this view shifted with United States v. Ross, where the Supreme Court upheld the warrantless search of a bag and pouch within an automobile, clarifying that the scope of such a search is determined by the probable cause regarding the items sought rather than the nature of the containers. Ross distinguished itself from earlier cases by noting that in those, officers lacked probable cause to search the entire vehicle, only the containers. In United States v. Johns, the Court further refined the automobile exception, permitting a warrantless search of packages in a pickup truck even if conducted three days after seizure, reiterating that probable cause justifies searching all areas of a vehicle that might conceal contraband. This principle allows for searches equivalent to those authorized by a warrant, acknowledging that an individual's privacy expectation in a vehicle diminishes when there is probable cause to suspect contraband transport. Subsequent cases in the Circuit have adhered to this definition of the automobile exception.

The application of the automobile exception to the Fourth Amendment is central to this case, which presents a blend of characteristics from both Sanders and Ross cases. Initially, the drug agents focused on the burgundy suitcases in the trunk of Sanchez's vehicle rather than the vehicle itself, akin to the Sanders case. However, agents Nardolillo and Villaruel had probable cause to believe that both the vehicle and the suitcases contained Ionamin, paralleling the Ross case. The court concludes that the facts align more closely with Ross, validating the warrantless search of the suitcases under the automobile exception. This exception is justified as the agents had probable cause for both the vehicle and its contents, and they were unaware of the suitcases containing Ionamin before observing them. The court emphasizes the need for caution in applying the automobile exception due to its potential to undermine the warrant requirement essential to Fourth Amendment protections. Ultimately, the decision of the district court denying Sanchez's motion to suppress is affirmed, confirming the legality of the search. The court refrains from commenting on the constitutionality of warrantless searches of luggage when law enforcement knows it contains contraband before it is placed in a vehicle but maintains probable cause to search the vehicle itself.