Search & seizure; Motion to suppress; Whether the initial traffic stop was supported by “probable cause”; Whether defendant’s warrantless arrest based on a misdemeanor was constitutional; Reasonableness; Virginia v Moore; Whether the warrantless search of his vehicle violated the Fourth Amendment; The “automobile exception” to the warrant requirement; Sufficiency of the evidence for a FIP conviction; 18 USC § 922(g)(1); Effect of defendant’s factual stipulations to the elements of his offense; Waiver; Witherspoon v United States; Lack of a guilty plea; Colloquy satisfying several of FedRCrmP 11’s requirements

The court held that the district court did not err by denying defendant-Watson’s motion to suppress drug and firearm evidence found in his vehicle where the traffic stop and his warrantless arrest were supported by probable cause, and the vehicle search was permissible under the automobile exception. It also held that there was sufficient evidence to support his FIP conviction. Watson was stopped for driving past the stop bar at a traffic light. After he refused to provide identification, he was placed under arrest. An officer saw a bag of marijuana in the vehicle through a window and a vehicle search resulted in the drug and firearm evidence. After he unsuccessfully moved to suppress the evidence, Watson “agreed to a bench trial based on stipulated facts” and was found guilty of FIP. He appealed the district court’s denial of his motion to suppress. The court first held that the officer had probable cause to stop Watson for driving past the stop bar at a traffic light. Watson’s video footage did not contradict the officer’s testimony, and the record offered no reason for the court to second-guess the district court’s determination as to the officer’s credibility. The court also held that Watson’s warrantless arrest was supported by probable cause where he had violated Ohio traffic laws by driving past a stop bar and driving on a suspended license. Watson had also refused to show the officer his driver’s license, likewise a violation of Ohio law. Watson argued that his warrantless arrest was unlawful because the driving on a suspended license offense was only a misdemeanor. But the Supreme Court previously rejected this argument in Moore. As for the warrantless search, the court held that it was permitted under the automobile exception. A bag of marijuana was spotted through the vehicle’s window. “Because there was a substantial probability that Watson possessed illegal contraband in violation of Ohio law, the officers were permitted to search the entirety of Watson’s vehicle, including any containers found inside [it], without a warrant.” Lastly, the court rejected his claim that there was insufficient evidence to convict him of FIP. His “factual stipulation to all essential elements of” the charge constituted “a waiver of his right to challenge the sufficiency of the evidence for his conviction.” The court noted that he “did not enter a guilty plea. Thus, Rule 11, by its terms,” did not apply. But the court has “encouraged district courts to conduct a colloquy, in compliance with Rule 11, when a defendant stipulates to each element of an offense.” The district court here “took appropriate and careful steps to confirm that Watson’s stipulation was knowing and voluntary.” Affirmed.