Motion To Suppress in El Paso

Case Study: Successful Motion to Suppress Evidence

On June 3, 2019, our client, Randall Wayne Melton, found himself at the center of a legal battle that ultimately hinged on the Fourth Amendment to the United States Constitution. Melton, the defendant in this case, was arrested in Hope, New Mexico, by Eddy County Sheriff Deputies without a warrant. The arrest followed the deputies’ use of Melton’s cell phone as a GPS tracking device to locate and detain him. This entire interaction was captured on the lapel videos of the officers.

The Backdrop

The circumstances leading up to Melton’s arrest were initiated by a call from Curtis Cherry, Tyson Terrell’s stepfather, to the Eddy County Sheriff’s office. Cherry had received a call from Terrell, during which a second male voice was heard. Cherry expressed uncertainty about the identity of this second male and whether they were a fugitive. In response, Lieutenant Joshua Baker initiated a GPS tracking operation on Terrell’s phone.

The tracking operation led the deputies from Carrizozo, New Mexico, through several locations, eventually culminating in a traffic stop in Hope, New Mexico, at approximately 01:45 on June 3, 2019. During this stop, Melton was detained without an arrest warrant, a detention that continued even after Tyson Terrell, (the wanted subject) was removed from the vehicle and arrested. The video evidence shows that Melton was advised of his rights and then informed that his vehicle would be searched “just because he [Terrell] is with him,” leading to his subsequent handcuffing.

Argument

Melton argued that the tracking and ultimate detention violated his Fourth Amendment rights in his motion to suppress. He contended that the deputies had tracked him for over two hours and detained him for 89 minutes without a warrant and any articulable reason beyond his association with Tyson Terrell.

a. Extended Traffic Stop Detention

Melton’s motion invoked the precedent set by Rodriguez v. United States, 575 U.S. 348 (2015), which established that the duration of a traffic stop should be determined by the seizure’s “mission” and safety concerns. While law enforcement can detain individuals pending an inquiry into a traffic violation, Melton argued that the continued detention, arrest, and transportation were based solely on guilt by association, with no articulable reasonable suspicion.

Melton further argued that the detention exceeded the time needed to handle the initial reason for the stop, violating the Fourth Amendment’s protections against unreasonable seizures, as outlined in Rodriguez.

b. Warrantless Tracking of Melton’s Cell Phone

Melton also challenged the warrantless tracking of his cell phone by Lieutenant Joshua Baker. He argued that his cell phone’s GPS data was obtained without a warrant and proper justification, despite Baker’s access to information that could have verified Melton’s innocence.

Citing Carpenter v. United States, 138 S. Ct. 2206 (2018), Melton asserted that individuals have a reasonable expectation of privacy in location data, including real-time GPS tracking. He argued that such tracking, without a warrant and a recognized exception, violated his Fourth Amendment rights.

Conclusion

Randall Melton’s successful motion to suppress evidence highlighted the government’s violation of his Fourth Amendment rights during tracking, detention, and arrest. The case raised significant concerns about the warrantless tracking of individuals through their cell phones and the arbitrary extension of detentions based on guilt by association rather than articulable reasonable suspicion.

Ultimately, the court recognized that these actions violated Melton’s Fourth Amendment rights, and the evidence obtained as a result of the illegal tracking and detention was suppressed. The suppression of the evidence led to the case’s dismissal by the United States Attorney’s Office. 

This case is a critical reminder of the importance of safeguarding constitutional protections in the digital age and ensuring that law enforcement adheres to established legal standards when conducting investigations.