The Tenth Circuit Court of Appeals published its opinion in United States v. Madden on Wednesday, June 20, 2012.
The Tenth Circuit affirmed the district court’s decision. Petitioner “pleaded guilty to one count of being a felon in possession of a firearm, reserving the right to appeal the district court’s denial of his motions to suppress and to quash the indictment for excessive delay. He argues the district court erred in denying his motion to suppress because his detention and the subsequent search of his vehicle violated the Fourth Amendment. He argues the district court abused its discretion by denying his motion to quash the indictment because a preindictment delay of four years violated his Fifth Amendment right to due process and his Sixth Amendment right to a speedy trial.”
The Court found that the “district court properly denied both motions. Neither [Petitioner]’s detention, nor the search of his vehicle, violated the Fourth Amendment. [His] investigatory detention was justified by articulable and reasonable suspicion and his subsequent arrest was supported by probable cause. Moreover, the search of [Petitioner]’s vehicle falls within the good-faith exception to the exclusionary rule. In addition, the preindictment delay did not violate the Fifth or Sixth Amendments. [Petitioner] failed to show the requisite prejudice to establish a violation of his Fifth Amendment right to due process. Furthermore, because the delay occurred prior to [his] indictment, his Sixth Amendment right to a speedy trial was not violated.”