United States v. Sigala-Baray

Summary

The court held that the officer had probable cause to arrest Sigala-Baray for failing to present proof of insurance after considering the totality of the circumstances, including the incorrect insurance document, the owner's statements and search efforts, and the apparent license-plate mismatch. The resulting search was therefore potentially valid as a search incident to a lawful arrest. The court vacated the suppression order and remanded for consideration of an alternative suppression argument that the district court had not addressed.