United States v. Sigala-Baray

Court of Appeals for the Tenth Circuit·Decided September 1, 2026·No. 25-1245·Unpublished

Opinion

FILED

United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT September 1, 2026

Christopher M. Wolpert

Clerk of Court

UNITED STATES OF AMERICA,

Plaintiff - Appellant,

v. No. 25-1245 (D.C. No. 1:25-CR-00011-NYW-1)

JORGE SIGALA-BARAY, (D. Colo.)

Defendant - Appellee.

ORDER AND JUDGMENT *

Before TYMKOVICH, MURPHY, and CARSON, Circuit Judges.

An arrest is lawful when an officer has probable cause to believe someone has committed or is about to commit a crime. Searches performed incident to lawful arrests do not violate the Fourth Amendment.

Colorado law requires drivers to present proof of insurance upon an officer’s request during a traffic stop. When a driver has not presented proof of insurance, and the facts would warrant a reasonable officer’s belief that this is because the driver does not possess such proof, the officer has probable cause to believe the driver has violated Colorado law.

*

This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.

Corporal Kyle Taylor stopped Defendant Jorge Sigala-Baray after noticing his vehicle had a broken taillight. Taylor asked Defendant and Sasha Sarmiento—the vehicle’s owner and front passenger—for proof of insurance. By the time Taylor searched Defendant more than five minutes later and found a handgun, neither he nor Sarmiento had presented proof of insurance. Taylor arrested Defendant and the government charged him for being a felon-in-possession of a firearm.

Defendant moved to suppress evidence from the search, arguing that Taylor violated his Fourth Amendment rights. The government argued that Taylor conducted his search incident to a lawful arrest because Taylor had probable cause to arrest Defendant for failing to present proof of insurance. The district court granted Defendant’s motion to suppress, and the government appealed. Exercising jurisdiction under 18 U.S.C. § 3731, we vacate and remand.

I.

This dispute arises from a traffic stop involving Taylor, Defendant, and Sarmiento. On August 10, 2024, Defendant drove past Taylor in a Ford Expedition with a broken taillight. 1 Taylor asked dispatch to run the vehicle’s license plate and initiated a traffic stop. After Taylor approached the vehicle, its front passenger— Sarmiento—identified herself as the owner.

1 We base our recitation of the facts in this case on the district court’s factual findings, which we accept “unless they are clearly erroneous.” United States v. Rice, 483 F.3d 1079, 1082 (10th Cir. 2007).

Taylor asked Sarmiento if she had “the insurance for [her] car,” to which she replied “[y]ou know, I don’t think I do, but I do have insurance, and I don’t know where my registration is.” Taylor suggested that Sarmiento check her phone for proof and began chatting with Defendant. Sarmiento looked for her insurance card in her purse.

About a minute later, Sarmiento provided an insurance document to Taylor, which he took back to his patrol car. This insurance document belonged to a different vehicle, so Taylor reapproached Defendant and Sarmiento about three minutes later and again asked for proof of insurance for the Expedition. Sarmiento began to look through her phone.

After about thirty seconds, Taylor asked Defendant and Sarmiento to step out of the car so he could check the Expedition’s Vehicle Identification Number (“VIN”). Taylor wanted to check the VIN because, by this time, dispatch had run the license plate for the Expedition and informed Taylor that the plate did not match the vehicle. 2 As Defendant exited the vehicle, Taylor searched him, found a gun in his waistband, and placed him under arrest. The government charged Defendant as a felon-in-possession of a firearm under 18 U.S.C. § 922(g)(1).

2 This turned out to be a mistake resulting from a transpositional error. Even still, this fact is relevant to the analysis below because we have “consistently held” that “objectively reasonable” mistakes of fact can support probable cause. See United States v. Herrera, 444 F.3d 1238, 1246 (10th Cir. 2006) (first citing United States v. Tibbetts, 396 F.3d 1132, 1138 (10th Cir. 2005); then citing United States v. DeGasso, 369 F.3d 1139, 1144 (10th Cir. 2004); then citing United States v. Vercher, 358 F.3d 1257, 1261 (10th Cir. 2004); and then citing Illinois v. Rodriguez, 497 U.S. 177, 179 (1990)).

II.

Defendant moved to suppress evidence related to Taylor’s warrantless search, claiming it violated his Fourth Amendment rights. The government opposed the motion, arguing that the Fourth Amendment permitted Taylor’s search because it occurred incident to a lawful arrest. According to the government, Taylor had probable cause to arrest Defendant at the time of the search under Colo. Rev. Stat. §§ 42-4-1409(2) and (3)(a). Section 42-4-1409(2) prohibits operating an uninsured vehicle. Section 42-4-1409(3)(a) requires vehicle operators to “present . . . immediate evidence” of insurance to a requesting officer during a traffic stop.

The district court granted the motion to suppress after determining that Taylor lacked probable cause to arrest Defendant. It reasoned that a defendant violates subsection (3)(a) when he “fails to” present proof of insurance. In the district court’s view, Defendant had not “failed to present evidence of valid insurance” at the time of the search because Sarmiento “was still actively searching for proof of insurance” and had only searched for about two minutes. “[F]or the same reason[s],” the district court concluded that Taylor lacked probable cause to arrest Defendant under subsection (2). The district court explained that any other conclusion would result in “an unreasonable and unjust interpretation” of these provisions. The government appealed. 3

3 The government also argued that Taylor had reasonable suspicion that Defendant was armed and dangerous, justifying the search under the Fourth Amendment. The district court rejected this argument and the government does not challenge this conclusion on appeal.

III.

“When reviewing a district court’s decision on suppression of evidence, we review the district court’s factual findings for clear error, viewing the evidence in the light most favorable to those findings.” United States v. Johnson, 584 F.3d 995, 998 (10th Cir. 2009) (citing United States v. Garcia, 459 F.3d 1059, 1062 (10th Cir. 2006)). We review the district court’s “ultimate determination of whether probable cause supported a search or seizure” de novo. United States v. Banks, 884 F.3d 998, 1007 (10th Cir. 2018) (quoting United States v. Hauk, 412 F.3d 1179, 1185 (10th Cir. 2005)).

The district court concluded that Taylor’s search violated Defendant’s Fourth Amendment rights. The Fourth Amendment, applicable to the states “through the Fourteenth Amendment’s Due Process Clause,” United States v. Canada, 76 F.4th 1304, 1307 (10th Cir. 2023) (citing Mapp v. Ohio, 367 U.S. 643, 650 (1961), “protects against unreasonable searches of ‘persons, houses, papers, and effects.’” Id. (quoting U.S. Const. amend. IV.) Under the exclusionary rule, courts may suppress evidence the government obtains in violation of the Fourth Amendment. See Utah v. Strieff, 579 U.S. 232, 237 (2016) (citing Mapp, 367 U.S. at 655)).

In determining whether an officer has violated the Fourth Amendment, “the ultimate touchstone . . . is ‘reasonableness’ . . . .” Brigham City, Utah v. Stuart, 547 U.S. 398, 403 (2006) (first citing Flippo v. West Virginia, 528 U.S. 11, 13 (1999); and then citing Katz v. United States, 389 U.S. 347, 357 (1967)). Warrantless searches are presumptively unreasonable, id. (quoting Groh v. Ramirez, 540 U.S.

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