Tenth Upholds Denial of Suppression in Case Involving "Tandem" Cars

U.S. v. Zamudio-Carrillo, --- F.3d ----, 2007 WL 2421760 (10th Cir. August 28, 2007)

Following up on and distinguishing United States v. Valenzuela, 365 F.3d 892, 896 (10th Cir.2004) in which the 10th found no probable cause to arrest Valenzuela on the belief she was traveling in tandem with another vehicle already stopped for drugs, the 10th upheld the district court determination that there was PC to arrest D, the driver of the tandem vehicle. Here, the drug and the tandem vehicles both had sequentially numbered out of state specialty license plates. The driver of the drug vehicle said she had recently purchased her vehicle and the cop inferred that the plates were sequential because the vehicles were purchased and licensed at the same time. Also, the drug vehicle driver denied she was traveling with another vehicle and tandem drug drivers usually deny they are traveling with another.