Sequentially numbered specialty license plates may provide reasonable suspicion of tandem travel and criminal activity

SEARCH & SEIZURE United States v. Zamudio-Carrillo, No. 06-3193, ___ F.3d ___ (10th Cir. Aug 28, 2007)(Kansas). Appeal of district court’s denial of motion to suppress evidence in conjunction with guilty plea to possession with intent to distribute heroin; traveling in interstate commerce to promote unlawful activity; and unlawful entry into United States by an alien in violation of 21 U.S.C. § 841(a)(1); 18 U.S.C. § 1952(a)(3); and 8 U.S.C. § 1325(a)(1). HELD: Trooper’s discovery of false compartment in detained vehicle coupled with trooper’s observation that second vehicle traveling nearby bore identical sequentially numbered out-of-state specialty license plate provided reasonable suspicion both vehicles were traveling in tandem and, thus, involved in criminal activity. Defendant’s vehicle was properly detained. Resulting search did not violate Fourth Amendment. Read the opinion here.