Background
Two West Virginia state troopers saw Alexander Galindo’s vehicle remain stopped at two green lights—first for about ten seconds and later for three to five seconds. Believing that Galindo had failed to obey an official traffic-control device in violation of West Virginia Code § 17C-3-4(a), the troopers stopped him.
After Galindo failed to provide identification, an officer ordered him out of the vehicle and conducted a pat-down. The officer then saw a clear ziplock bag containing white powder in plain view inside the open driver’s-side door. A vehicle search uncovered a loaded firearm and other contraband. Galindo, a convicted felon, was charged under 18 U.S.C. § 922(g)(1).
The district court denied Galindo’s motion to suppress, crediting the troopers’ account and concluding that the initial ten-second pause violated West Virginia traffic law, giving the officers probable cause for the stop. Galindo pleaded guilty while preserving his right under the plea agreement to appeal that ruling.
The Court’s Holding
The Fourth Circuit affirmed the denial of Galindo’s suppression motion. Reviewing legal conclusions de novo and factual findings for clear error, the court found no reversible error in the district court’s decision.
The court reiterated that an automobile stop is reasonable when officers have probable cause to believe a traffic violation occurred. It held that Galindo supplied no basis to disturb the district court’s credibility determinations concerning his pauses at the green lights or to reject its interpretation that the ten-second pause violated West Virginia Code § 17C-3-4(a).
Key Takeaways
- A district court’s factual findings on a suppression motion, including credibility determinations, are reviewed only for clear error.
- Probable cause to believe a traffic violation occurred makes the initial automobile stop reasonable under the Fourth Amendment.
- The Fourth Circuit left intact the ruling that Galindo’s approximately ten-second delay at a green light violated West Virginia Code § 17C-3-4(a).
Why It Matters
The decision illustrates how a brief failure to proceed at a green light can provide probable cause for a traffic stop when treated as disobedience of a traffic-control device under applicable state law. It also underscores the difficulty of overturning a suppression ruling that depends on a trial court’s credibility findings.
Because the opinion is unpublished, it is not binding precedent in the Fourth Circuit.