USA v. Bradley

Bradley was pulled over by state police when a trooper observed Bradley weave in and out of traffic. During the stop, Bradley admitted his license was suspended. After approx. ten more minutes of questioning, Bradley admitted there was cocaine in the trunk of his car. The trooper searched the trunk and confiscated a kilo of cocaine. Bradley filed a suppression motion and argued Trooper Johnson had unlawfully prolonged the traffic stop, and that the stop involved a custodial interrogation without the benefit of Miranda warnings. The District Court granted Bradley’s Motion. The government appealed, and the 3rd Circuit Court reversed and remanded.

The Court found the government established through dashcam evidence and the testimony of the trooper that Bradley was driving on a suspended license, that he, therefore, could not continue driving the car, that police procedure called for the vehicle to be towed and impounded, and that necessarily there would have been an inventory search that would have revealed the cocaine.