United States v. Eric Alan Mayo

Eric Mayo appeals the district court’s denial of his motion to suppress evidence found in a search of his vehicle. While responding to a call about suspicious narcotics activity, officers arrested Mayo for a felony violation of California’s vehicle code. The officers searched Mayo’s car incident to this arrest, finding bags of stolen mail. Mayo seeks to suppress this evidence on the grounds that officers: (1) lacked reasonable suspicion to detain him, (2) unreasonably broadened the length and scope of their investigation during his detention, (3) lacked probable cause to arrest him on the vehicle code violation, and (4) expanded the scope of the search incident to arrest beyond constitutional limits when they searched the hatchback area of his car.

We reject all four claims, and affirm the judgment of the district court. In doing so, we join other circuits in ruling that, for purposes of an automobile search incident to arrest, officers may search the cargo area behind the rear seat of a hatchback vehicle.

Facts

On July 16, 2002,. Officer Fritts of the Stockton Police Department Narcotics Unit received a call from the manager of a Super-8 Motel. The manager reported suspicious…