United States v. John Qualls

• Court: Court of Appeals for the Eighth Circuit
• Decided: June 13, 2025
• Docket: 24-1502
• Status: Unpublished

Opinion

United States Court of Appeals For the Eighth Circuit ___________________________

No. 24-1502 ___________________________

United States of America

Plaintiff - Appellee

v.

John Trinidad Qualls

Defendant - Appellant ____________

Appeal from United States District Court for the Northern District of Iowa - Eastern ____________

Submitted: February 13, 2025 Filed: June 13, 2025 [Unpublished] ____________

Before COLLOTON, Chief Judge, BENTON and STRAS, Circuit Judges. ____________

PER CURIAM.

John Qualls conditionally pleaded guilty to possessing drugs after officers discovered two bags of methamphetamine during a traffic stop. See 21 U.S.C. § 841(a)(1), (b)(1)(A). Although he argues the search violated the Fourth Amendment, we affirm. After getting pulled over for speeding, Qualls handed over a pouch containing his insurance card and registration. The pouch also had marijuana residue inside, and the officer detected its odor on the documents. Upon further questioning, Qualls admitted that he had smoked marijuana earlier in the day. The officer then spotted even more marijuana residue on the center console. At that point, he searched the car and found the methamphetamine. Qualls thought there was no probable cause for the search. The district court1 concluded otherwise, and so do we. See United States v. Merrett, 8 F.4th 743, 748 (8th Cir. 2021) (applying de novo review to a probable-cause determination).

Once Qualls turned over the pouch, the officer had reason to suspect drugs could be in the car. Add Qualls’s admission that he smoked marijuana earlier in the day and the residue on the car’s center console, and the officer reasonably “believe[d] that contraband [was] located inside the vehicle.” United States v. Oliver, 950 F.3d 556, 563 (8th Cir. 2020) (citation omitted); see United States v. Smith, 990 F.3d 607, 612 (8th Cir. 2021) (holding that “the smell of marijuana” and a “marijuana cigarette” in a passenger’s jacket provided probable cause for a car search); United States v. Brown, 634 F.3d 435, 438 (8th Cir. 2011) (finding probable cause based on a passenger’s admission that he smoked marijuana earlier in the day). We accordingly affirm the judgment of the district court. ______________________________

1 The Honorable C.J. Williams, then District Judge, now Chief Judge, United States District Court for the Northern District of Iowa, adopting the report and recommendation of the Honorable Mark A. Roberts, United States Magistrate Judge for the Northern District of Iowa. -2-