D.N.M.: Truck inspection stop valid admin search under Burger

The New Mexico regulatory scheme for truck inspections has already been held to satisfy Burger. Stopping defendants’ truck for inspection at an inspection station was reasonable under that standard. On opening the trailer to compare to the bills of lading, the smell of over a ton of marijuana was apparent. That authorized a further search. The detention before that was reasonable under the administrative scheme. The court finds a Miranda violation for the password on their cell phones, so that is suppressed, and inevitable discovery doesn’t apply. United States v. Coleman, 2021 U.S. Dist. LEXIS 153161 (D.N.M. Aug. 12, 2021).

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