United States v. Erickson Campbell (11th Cir. August 2020)

The Federal Docket

September 17, 2020

Fourth Amendment/Unlawfully Prolonged Stop – The exclusionary rule does not apply if the officer diligently investigated, worked expeditiously, and reasonably relied on prior court rulings while conducting an otherwise valid traffic stop.

The Court reconsidered its prior holding in US v. Campbell from January 2019, where it held that suppression was warranted because the officer impermissibly prolonged the stop by asking questions unrelated to the stop.

This time around, the Court held that the exclusionary rule did not apply because the officer had “‘diligently investigated’ the traffic violations and ‘expeditiously’ completed the citations.” The Court further held that the officer “acted in ‘objectively reasonable reliance on binding appellate precedent.’”

Appeal from the Middle District of Georgia

Opinion by Tjoflat, joined by Martin and Murphy (by designation from E.D. Mich.)

Click here to read the opinion.

Tom Church - Tom is a trial and appellate lawyer focusing on criminal defense and civil trials. Tom is the author of "The Federal Docket" and is a contributor to Mercer Law Review's Annual Survey in the areas of federal sentencing guidelines and criminal law. Tom graduated with honors from the University of Georgia Law School where he served as a research assistant to the faculty in the areas of constitutional law and civil rights litigation. Read Tom's reviews on AVVO. Follow Tom on Linkedin.

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