United States v. Leonardo Triana (11th Cir. 2019) (Unpublished)

The Court affirmed the district court’s denial of a motion to suppress, holding that the traffic stop at issue was not unlawfully prolonged but rather became a consensual encounter. The Court held that a reasonable person would have felt free to leave based on the circumstances, which included the patrolman issuing the defendant a written warning and the defendant subsequently asking questions about where to fix his vehicle after receiving the warning.

United States v. Erickson Campbell (11th Cir. January 2019)

The Court overruled its prior “overall reasonableness” standard for prolonged stops and held that officer’s traffic stop was unreasonably prolonged by the officer asking questions unrelated to the stop. The Court further held that the good faith exception made suppression unwarranted despite the government waiving this issue on appeal.
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