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Media Alerts - United States v. Taylor -- Fourth Circuit
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November 3, 2014
  United States v. Taylor -- Fourth Circuit
Headline: Passenger's Hesitation Allows for Warrantless Search at Airport Jet Way

Area of Law: Criminal Law

Issue Presented: Whether the district court's denial of a motion to suppress $102,000 that had been seized on an airport jet way as well as statements made by the defendant during a subsequent booking violated the Fourth Amendment protection against unreasonable searches and seizures.

Brief Summary: Homeland Security Investigations received a tip that Yvonne Taylor would attempt to smuggle a large amount of currency while traveling from Baltimore, Maryland, to Montego Bay, Jamaica. Officers stationed themselves inside the jet way gate and began interviewing passengers as they were boarding the Montego Bay-bound flight. When Taylor was questioned, she hesitated and gave a response that was seemingly different when compared to the other previously-questioned passengers. Taylor also gave inconsistent statements after officers asked her additional questions. Taylor ultimately admitted she was carrying over $100,000 on her person. Officers escorted Taylor to a secondary area where a pat-down search yielded $102,000 in cash hidden around her midsection. While the officer was filling out the booking form, Taylor volunteered that she had carried bulk sums of currency on two prior trips. She also volunteered that the money would have been deposited in a bank had she not been caught. On appeal, Taylor challenged the trial court's refusal to suppress the money and statements.

The U.S. Court of Appeals for the Fourth Circuit held that the Ramsey border search exception extends to all routine searches at the nation's borders. The initial stop and questioning of Taylor on the jet way therefore comported with the Fourth Amendment. Furthermore, the panel concluded that the officers had probable cause to arrest Taylor and conduct a warrantless search incident to that lawful arrest. Taylor's hesitation, awkward response when initially questioned, aversion to eye contact during questioning, and inconsistent answers regarding the amount of currency she was carrying all factored into the officer's reasonable belief that Taylor was or would be involved in criminal activity.

To read the full text of the opinion, please click here.

Panel: Judges Wynn and Diaz; Judge Hamilton, Senior Circuit Judge.

Date of Issued Opinion: September 24, 2014

Docket Number: 13-4507

Decided: Affirmed

Case Alert Author: Alexandra A. Stulpin

Counsel: Lance C. Hamm, Houston, Texas, for Appellant. Rod J. Rosenstein, United States Attorney, Evan T. Shea, Assistant United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Baltimore, Maryland, for Appellee.

Author of Opinion: Per Curiam

Case Alert Circuit Supervisor: Professor Renée Hutchins

    Posted By: Renee Hutchins @ 11/03/2014 12:10 PM     4th Circuit  

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