In these consolidated appeals, Garner and his codefendant appealed the denial of their motion to suppress evidence recovered after a car stop. Garner also appealed the District Court’s admission at trial of his prior drug conviction. The Third Circuit Court affirmed.
On appeal, the defendants argued the trooper unlawfully extended the traffic stop. The 3rd Circuit disagreed, holding the trooper had reasonable suspicion to extend the stop based on information he obtained during the first few minutes of the traffic stop and before he engaged in an unrelated investigation. Moreover, the Court held that Garner’s 2007 drug conviction showed that he had personal knowledge about how to identify cocaine, how to traffic it, and how to package, price, and purchase it. Thus, the conviction was admissible pursuant to Fed.R.Crim.P. 404(b).