United States of America v. Anthony Thomas Lee Baker

United States Court of Appeals
For the Eighth Circuit
___________________________
No. 25-2041
___________________________
United States of America
Plaintiff - Appellee
v.
Anthony Thomas Lee Baker
Defendant - Appellant
____________
Appeal from United States District Court
for the District of South Dakota - Northern
____________
Submitted: February 13, 2026
Filed: July 9, 2026
[Unpublished]
____________
Before LOKEN, LAVENSKI R. SMITH, and STRAS, Circuit Judges.
____________
PER CURIAM.
An officer of the Watertown Police Department observed Anthony Baker
driving a black Chevrolet pickup in Watertown, South Dakota. The officer stopped
Baker because snow obstructed his license plate and covered the registration sticker.

-- 1 of 5 --

-2-
The officer approached Baker and requested his driver’s license and proof of
insurance. Baker had neither but instead provided a tribal identification card. Baker
appeared nervous and evasive. The officer instructed him to exit the vehicle and sit
in the patrol car. Baker sat partially inside the vehicle. The officer noticed a pill
bottle on a snowbank next to the patrol car, close to where Baker had been resting.
Baker denied ownership of the bottle, and the officer detained him. The officer found
marijuana in Baker’s vehicle, and Baker admitted that it was his. Baker additionally
disclosed that there was a firearm hidden in the truck and that he was a felon.
After a records check, the officer determined that Baker’s driver’s license had
been revoked and that Baker had an outstanding felony arrest warrant. He arrested
Baker pursuant to the warrant, and a subsequent search of the vehicle revealed the
firearm and other drug-related items. The entire encounter lasted approximately
eight minutes.
Baker moved to suppress the evidence obtained during the stop. The district
court1 denied the motion. Baker conditionally pleaded guilty to being an unlawful
user in possession of a firearm, in violation of 18 U.S.C. § 922(g)(3). Baker reserved
his right to pursue this appeal. This appeal followed.
We apply a mixed standard of review to the denial of a motion to suppress.
United States v. Smith, 820 F.3d 356, 359 (8th Cir. 2016). “The trial court’s findings
of fact are reviewed for clear error and its denial of the suppression motion is
reviewed de novo.” United States v. Ford, 888 F.3d 922, 925 (8th Cir. 2018). “We
will affirm unless the denial of the motion is unsupported by substantial evidence, is
based on an erroneous interpretation of the law, or it is clear, based on the entire
record, that a mistake was made.” United States v. Walker, 840 F.3d 477, 483 (8th
Cir. 2016).
1 The Honorable Roberto A. Lange, Chief Judge, United States District Judge
for the District of South Dakota.

-- 2 of 5 --

-3-
Baker argues that the traffic stop violated the Fourth Amendment because the
officer lacked an objectively reasonable basis to believe South Dakota law had been
violated. Baker also argues that the underlying statute, S.D. Codified Laws § 32-5-
98, requires only that license plates be visible, not registration stickers.
The Fourth Amendment provides that “[t]he right of the people to be secure
in their persons, houses, papers, and effects, against unreasonable searches and
seizures, shall not be violated.” U.S. Const. amend. IV. “[S]topping an automobile
and detaining its occupants constitute a ‘seizure’ within the meaning of” the Fourth
Amendment. Delaware v. Prouse, 440 U.S. 648, 653 (1979). “As a general matter,
the decision to stop an automobile is reasonable where the police have probable
cause to believe that a traffic violation has occurred.” Whren v. United States, 517
U.S. 806, 810 (1996). Even minor traffic violations create sufficient cause to stop
the vehicle. Id.
Here, the officer initiated the traffic stop because of a suspected violation of
S.D. Codified Laws § 32-5-98, which provides, in relevant part:
Except as otherwise specifically provided, no person may operate or
drive a motor vehicle on the public highways of this state unless the
vehicle has a distinctive number assigned to it by the department, and
two number plates, bearing the number conspicuously displayed,
horizontally and in an upright position, one on the front and one on the
rear of the vehicle, each securely fastened.
At the suppression hearing, the arresting officer testified that snowfall had
ceased about 9.5 hours before the stop occurred and that the roadways had been
cleared. He believed that sufficient time had elapsed to reasonably expect drivers on
the roadways to have their plates clear and free of ice or snow. Under South Dakota
Law, a “driver’s failure to display prominently a registration sticker, alone, would
provide an officer with reasonable suspicion sufficient to justify at the very least an
investigatory stop.” United States v. Dumas, 94 F.3d 286, 290 (7th Cir. 1996)
(citation modified) (applying Illinois law); State v. Vento, 604 N.W.2d 468, 471

-- 3 of 5 --

-4-
(S.D. 1999) (extending the Dumas reasoning to South Dakota); see generally United
States v. Gilson, 654 F. App’x 247, 248 (8th Cir. 2016) (unpublished per curiam)
(upholding lawfulness of a stop when applying an Iowa statute requiring drivers to
securely fasten registration plates “in a place and position to be clearly visible and
shall be maintained free from foreign materials and in a condition to be clearly
legible.”). It is undisputed that snow partially obstructed Baker’s license plate. The
district court properly concluded that the officer had a reasonable basis for the stop.
Baker also argues that, even if the stop was initially lawful, it became
unconstitutional when the officer failed to simply confirm that the registration
sticker was valid. He contends that the officer’s questions and document requests
unrelated to the ongoing traffic violation impermissibly extended the stop in
violation of the Fourth Amendment. We disagree.
Beyond determining whether to issue a traffic ticket, an officer’s
mission includes ordinary inquiries incident to the traffic stop.
Typically such inquiries involve checking the driver’s license,
determining whether there are outstanding warrants against the driver,
and inspecting the automobile’s registration and proof of insurance.
These checks serve the same objective as enforcement of the traffic
code: ensuring that vehicles on the road are operated safely and
responsibly.
Rodriguez v. United States, 575 U.S. 348, 355 (2015) (citation modified). When
complications arise during these checks, “police may reasonably detain a driver for
a longer duration than when a stop is strictly routine.” United States v. Olivera-
Mendez, 484 F.3d 505, 510 (8th Cir. 2007). Relatedly, “[a]n officer may expand the
scope of a traffic stop beyond the initial reason for the stop and prolong the detention
if the driver’s responses and the circumstances give rise to a reasonable suspicion
that criminal activity unrelated to the stop is afoot.” United States v. Chavez Loya,
528 F.3d 546, 553 (8th Cir. 2008). We expect officers to base their suspicion on
“particularized, objective facts which, taken together with rational inferences from
those facts, reasonably warrant [] suspicion that a crime [is] being committed.”

-- 4 of 5 --

-5-
United States v. Jones, 269 F.3d 919, 927 (8th Cir. 2001) (alterations in original)
(quoting United States v. Beck, 140 F.3d 1129, 1136 (8th Cir. 1998)).
Here, the “totality of the circumstances” warranted reasonable suspicion on
the part of the officer. See id. While performing those “ordinary inquiries,”
Rodriguez, 575 U.S. at 355, the arresting officer encountered a driver unable to
furnish identification or insurance and who behaved suspiciously when asked to sit
in the patrol car, see United States v. White, 81 F.3d 775, 778 (8th Cir. 1996) (holding
that officers may request drivers to sit in the patrol car). Baker’s contraband, criminal
record, and “nervousness and lack of eye contact” provide a basis for reasonable
suspicion. United States v. Callison, 2 F.4th 1128, 1132 (8th Cir. 2021) (citing
United States v. Foley, 206 F.3d 802, 804, 806 (8th Cir. 2000)). No Fourth
Amendment violation occurred.
We affirm.
______________________________

-- 5 of 5 --