Defendants contend that the evidence seized as a result of the stop and subsequent search is inadmissible under the Fruit of the Poisonous Tree doctrine. The Court will handle each argument in turn.
II. Analysis
A. Initial Traffic Stop
Defendants argue first that the initial traffic stop violated their constitutional rights for two reasons: (1) Trooper Short lacked probable cause to initiate the stop, and (2) the stop was pretextual. It is well settled that a traffic stop is a "seizure" that implicates Fourth Amendment protections, and therefore the stop must be reasonable. Whren v. United States, 517 U.S. 806, 809-10 (1996). A traffic stop is reasonable if based on probable cause or reasonable suspicion. United States v. Washington, 455 F.3d 824, 826 (8th Cir. 2006). Any traffic violation, no matter how minor, provides probable cause to stop a driver. United States v. Martinez, 358 F.3d 1005, 1009 (8th Cir. 2004). However, the question is not whether the defendant actually violated a traffic law, but whether an objectively reasonable officer could have concluded the defendant committed a traffic violation. See United States v. Martin, 411 F.3d 998, 1001 (8th Cir. 2005). Indeed, even if the officer was mistaken in concluding that a traffic violation occurred, the stop does not violate the Fourth Amendment if the mistake was an objectively reasonable one. Washington, 455 F.3d at 826; see also United States v. Herrera-Gonzalez, 474 F.3d 1105, 1109 (8th Cir. 2007) ("The constitutional reasonableness of a traffic stop does not depend on the actual motivations of the officer . . . and the subjective intentions of the officer making the stop are irrelevant in determining the validity of the stop."); Martin 411 F.3d at 1001-02.
Defendants' argument that the traffic stop was pretextual is immaterial to determining whether the stop was reasonable. The question rather is whether it was objectively reasonable for Trooper Short to conclude that Defendants were violating a traffic law. See Martin, 411 F.3d at 1001.
