The defendant was pulled over after a trooper observed the defendant weave in and out of traffic. During the stop, the defendant admitted his license was suspended. After approx. ten more minutes of questioning, the defendant admitted there was cocaine in the trunk of his car. The trooper searched the trunk and confiscated a kilo of cocaine. The defendant filed a suppression motion and argued the trooper had unlawfully prolonged the traffic stop, and that the stop involved a custodial interrogation without the benefit of Miranda warnings. The District Court granted the suppression. The 3rd Circuit Court reversed and remanded.
The 3rd Circuit found the government established that the defendant was driving with a suspended license, that he, therefore, could not continue driving the car, that police procedure called for the vehicle to be towed as well as impounded, and that necessarily there would have been an inventory search that would have revealed the cocaine.