United States v. Britton, No. 23-1700 (8th Cir. 2024)
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The defendant, Antjuan Dante Britton, was convicted of possession with intent to distribute a controlled substance and conspiracy to possess with intent to distribute a controlled substance. He was sentenced to 240 months in prison and 10 years of supervised release. Britton appealed the denial of his pretrial motion to suppress evidence obtained from a search of his vehicle.
Prior to his arrest, law enforcement received information from a tipster and two women arrested for possession of methamphetamine, all of whom identified Britton as their source of the drug. The information provided by these individuals was corroborated by law enforcement, including details about Britton's rental vehicle and his stays at a local hotel. A controlled buy was arranged with Britton, but the deal fell through. However, Britton was arrested at the location of the planned deal, and his vehicle was searched, leading to the discovery of a pound of methamphetamine.
Britton argued that his arrest and the subsequent search of his vehicle were not supported by probable cause. The United States District Court for the District of North Dakota denied his motion to suppress the evidence obtained from the search. The court found that the corroborated information from the tipster and the two women, along with Britton's arrival at the planned drug deal, provided probable cause for his arrest and the search of his vehicle.
On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The appellate court agreed that the totality of the circumstances, including the corroborated information and Britton's actions, provided probable cause for his arrest and the search of his vehicle. The court noted that a warrantless arrest and a vehicle search under the automobile exception are permissible if supported by probable cause.
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