CASE SUMMARIES
Circuit Courts of Appeals Eighth Circuit
United States v. Puckett, No. 24-1293 (8th Cir. 2025)
Missouri State Highway Patrol Trooper James Rorie stopped the defendant, Billy Puckett, for traffic violations. During the stop, Puckett disclosed his status as a registered sex offender due to a prior statutory rape conviction. Trooper Rorie invited Puckett into his patrol vehicle while verifying his license and registration. Upon reviewing Puckett’s criminal history, the trooper noted that Puckett had not registered any social media accounts as was required for sex offenders.
After confirming the validity of Puckett’s license, the trooper requested and obtained consent to search Puckett’s vehicle. During the search, Trooper Rorie observed a cell phone in the vehicle, which illuminated as he picked it up, revealing Facebook and Snapchat app icons. This observation led the trooper to request consent to search the phone. After some equivocating from Puckett, he granted consent. While examining the phone, the trooper discovered an image he believed to be child pornography, leading to Puckett’s arrest and administration of Miranda warnings.
On appeal, Puckett challenged the lawfulness of the traffic stop’s extension, the search and seizure of his phone, and the lack of Miranda warnings prior to custodial interrogation. The court ruled in favor of the government on all counts.
The court held that the brief extension of the stop to request consent to search the vehicle was permissible, as the trooper had not yet issued a citation or warning, and the defendant had not returned to his vehicle. The court also found that the trooper’s observation of the phone screen, revealing social media apps in plain view, provided reasonable suspicion to extend the stop further.
Regarding the phone’s seizure, the court determined that the trooper’s action of picking up the phone did not constitute a meaningful interference with Puckett’s possessory interest and was reasonable within the scope of the vehicle search. Since the trooper did not manipulate or power the phone, the court held that no Fourth Amendment violation occurred. Additionally, the court found Puckett’s consent to search the phone was valid, as the trooper remained cordial and did not exert undue pressure.
Finally, the court concluded that Puckett was not in custody for Miranda purposes prior to his arrest, as he was not restrained in a manner indicative of custodial interrogation.
For the court’s opinion: https://cases.justia.com/federal/appellate-courts/ca8/24-1293/24-1293-2025-06-11.pdf
