United States of America v. John Trinidad Qualls

United States Court of Appeals
For the Eighth Circuit
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No. 24-1502
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United States of America
Plaintiff - Appellee
v.
John Trinidad Qualls
Defendant - Appellant
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Appeal from United States District Court
for the Northern District of Iowa - Eastern
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Submitted: February 13, 2025
Filed: June 13, 2025
[Unpublished]
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Before COLLOTON, Chief Judge, BENTON and STRAS, Circuit Judges.
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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.

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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.
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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.

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