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Draft a motion to suppress evidence. Client was stopped on I-95 without reasonable suspicion.

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Found 3 Fourth Amendment precedents

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Motion to Suppress Evidence

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I've drafted your motion. It argues the stop violated the Fourth Amendment on three grounds, citing Terry v. Ohio, Wong Sun, and Rodriguez v. United States. Click the document to review and edit.

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Case Files

Pleadings3 items

Discovery12 items

Police Report.pdf2.4 MB

Arrest Report.pdf1.8 MB

Witness Statement.docx456 KB

Miranda_Waiver.pdf124 KB

Lab_Results.pdf890 KB

Traffic_Stop_Video.mp4

What does the video footage show about the traffic stop? Are there any inconsistencies with the police report?

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Analyzing Traffic_Stop_Video.mp4 and Police_Report.pdf...

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Compared video footage with police report

The video footage shows Officer Whitfield stated "driving slowly" as the sole reason for the stop — but the police report claims "erratic lane changes." These accounts directly contradict each other.

The video also shows your client invoked right to counsel at 11:51 PM, just 9 minutes into the stop. The K-9 unit didn't arrive until 12:04 AM — 13 minutes after the invocation.

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Draft a motion to suppress the evidence from the traffic stop. Use the case files I uploaded.

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Motion to Suppress Evidence

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Motion to Suppress Evidence

MOTION TO SUPPRESS EVIDENCE

State v. Rodriguez, Case No. 2026-CR-0847

COMES NOW the Defendant, Marcus Rodriguez, by and through undersigned counsel, and respectfully moves this Honorable Court to suppress all evidence obtained as a result of the traffic stop conducted on Interstate 95 on January 14, 2026, and in support thereof states as follows:

I. STATEMENT OF FACTS

On January 14, 2026, at approximately 11:42 PM, Officer James Whitfield of the State Highway Patrol initiated a traffic stop of Defendant's vehicle on I-95, mile marker 127. The officer's report states only that the vehicle was "driving slowly in the right lane."

Following the stop, which lasted approximately 22 minutes, a K-9 unit was called to the scene. The resulting search yielded items that form the basis of the charges in this case.

II. LEGAL ARGUMENT

A. The Traffic Stop Lacked Reasonable Suspicion

The Fourth Amendment protects against unreasonable searches and seizures. Terry v. Ohio, 392 U.S. 1, 20 (1968). An officer must have "specific and articulable facts" establishing reasonable suspicion before conducting a traffic stop.

The officer's report states only that the vehicle was "driving slowly in the right lane."

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ToADA Katherine Park <k.park@da.state.gov>

SubjectRe: Discovery Request — State v. Rodriguez

Counselor,

We have not yet received the dashcam footage referenced in Officer Whitfield's supplemental report filed on February 12, 2026. Pursuant to Brady v. Maryland, 373 U.S. 83 (1963), the State is obligated to disclose all material evidence favorable to the defense.

The video footage already produced contradicts statements in the officer's report regarding the stated reason for the stop. The dashcam footage may contain additional exculpatory evidence and must be produced without further delay.

Please confirm receipt and provide a production timeline by end of day March 18, 2026.

Respectfully,
Sarah Chen, Esq.

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