D.S.D.: If bad driving alone wasn’t RS, his leaving a drug house and being known have prior drug arrests made it RS

Here, defendant allegedly drove left of center and he challenges that as the basis of the stop. The court doesn’t agree and goes one further, prior drug arrests and just leaving a drug house added to the driving was reasonable suspicion. United States v. Spaid, 2017 U.S. Dist. LEXIS 178391 (D.S.D. Oct. 27, 2017):

In any event, this Court agrees with Judge Moreno that even if Spaid twice crossing the center line was not enough to justify the stop, the totality of the circumstances gave the deputies reasonable suspicion. The deputies observed Spaid, whom Deputy Gross had twice arrested for drug use, leave a suspected drug house and start driving his truck. Spaid stopped his vehicle to the left of the center line on Capitol Avenue and then twice crossed the center line while driving on Garfield Street. Deputy Gross testified that crossing the center line can be an indication that the driver is impaired. T. at 47, 53-54. Although a suspect’s criminal history and presence at a drug house is not enough by itself to create reasonable suspicion, United States v. Spears, 636 F. App’x 893, 899 (5th Cir. 2016); United States v. Santos, 403 F.3d 1120,1132 (10th Cir. 2005), the totality of the circumstances here—namely, Spaid’s prior drug arrests, visit to the suspected drug house, and his driving after leaving the house—gave the deputies reasonable suspicion to stop him.