Collective Knowledge and Stash‑House Nexus Suffice for a Vehicle Stop: United States v. Amado (1st Cir. 2025)

Introduction

In United States v. Amado, the First Circuit affirmed both the convictions and a 384-month aggregate sentence imposed on Aderito Patrick Amado for his role in a major South Shore (Massachusetts) drug-trafficking organization (DTO). The appeal raised two principal issues:

Fourth Amendment: whether officers had reasonable suspicion to conduct a warrantless stop of a blue Jeep Grand Cherokee shortly after an apparent re‑supply (“re‑up”) at a known stash apartment (Unit 401, 35 Audubon Road, Weymouth) for which a state search warrant had issued.
Sentencing: whether the district court erred by applying an obstruction-of-justice enhancement (U.S.S.G. § 3C1.1) and a career-offender designation (U.S.S.G. § 4B1.1), and whether the sentence was substantively unreasonable in light of a co‑defendant’s lower sentence.

Against a detailed investigatory backdrop — including months of surveillance, controlled fentanyl buys, and corroborative lease, GPS, and cell phone evidence tying Amado to two “stash” apartments — the First Circuit (Lynch, J.) held that the stop was supported by reasonable suspicion under the collective knowledge doctrine, and that none of Amado’s sentencing claims warranted relief. The decision consolidates several strands of Fourth Amendment and sentencing doctrine: (1) reasonable suspicion may rest on a team’s collective knowledge where contemporaneous communications convey the relevant facts; (2) observed “re‑up” behavior at a stash location — even in a large, multi‑unit complex — supports a stop when paired with a specific nexus; and (3) sentencing arguments not preserved (or not framed as plain error on appeal) are forfeited or waived, and claims of co‑defendant disparity must be “apples-to-apples.”

Summary of the Opinion

Motion to Suppress: Affirmed. The task force had reasonable suspicion to stop the Jeep driven by Amado. The stop was justified by the team’s collective knowledge: ongoing DTO surveillance, search warrants for the two stash apartments leased to Amado’s girlfriend (Lopes), the Jeep’s documented ties to those apartments (including being listed on the Ricciuti lease), its prior appearance at the exact staging area for “re‑ups,” and contemporaneous observations of a passenger acting as a lookout and a quick exchange of a green bag with a building occupant (Erica Vieira). Amado had abandoned any challenge to the subsequent ordering-out, frisk, and vehicle search.
Obstruction-of-Justice Enhancement (§ 3C1.1): Affirmed. The district court acted within its discretion in finding that Amado perjured himself by falsely minimizing his involvement with the Audubon stash apartment — a material subject at trial — notwithstanding partial admissions about other drugs and firearms. Amado’s separate claim that the court failed to make the specific findings contemplated by Dunnigan (1993) was forfeited for lack of preservation.
Career-Offender Designation (§ 4B1.1): No relief. Amado’s argument that two prior Massachusetts drug convictions should have been treated as a single conviction (no “intervening arrest”) was not raised below and, because his appellate briefing did not even invoke plain-error review, was waived. In any event, any error would be harmless because the designation did not affect the advisory range the district court ultimately used.
Substantive Reasonableness: No relief. Amado’s disparity argument based on co‑defendant Kevin Cardoso’s 188‑month sentence was waived (not properly developed below or on appeal) and unpersuasive in any event given material differences: Guidelines exposure, criminal history, a guilty plea (Cardoso), and sentencing by a different judge.
Disposition: Convictions and sentence affirmed.

Analysis

Precedents Cited and How They Informed the Decision

United States v. Kimball (1st Cir. 1994) and United States v. Walker (1st Cir. 1991): The court reprises the familiar two‑step Terry framework for vehicle stops: (1) whether the stop was justified at inception by reasonable suspicion, and (2) whether ensuing actions were reasonably related in scope. Amado only contested step one on appeal.
United States v. Pavao (1st Cir. 2025) and United States v. Millette (1st Cir. 2024): Standards of review. The First Circuit reviews de novo the legal determination of reasonable suspicion, while accepting factual findings unless clearly erroneous — a standard the court called “exceedingly deferential.”
United States v. Brown (1st Cir. 2010): Deference to trained officers’ interpretations of behavior in the field; their observations need not be correct to support reasonable suspicion.
Illinois v. Wardlow (U.S. 2000): Reasonable suspicion may arise from observed conduct even when officers do not know a suspect’s identity — answering Amado’s argument that lack of recognition of the Jeep’s occupants undermined reasonable suspicion.
United States v. Flores Perez (1st Cir. 1988): Reasonable suspicion supported where officers witnessed a seemingly prearranged pickup (here, the short exchange of a green bag at the very doorway and spot previously used for “re‑ups”).
United States v. Sheckles (6th Cir. 2021): Sister-circuit support for stopping vehicles seen departing a residence subject to a search warrant; the First Circuit notes this line of authority as persuasive in the context of the Jeep’s departure from a known stash site with an active warrant.
United States v. Cruz-Rivera (1st Cir. 2021) and United States v. Azor (1st Cir. 2017): The collective knowledge doctrine. Reasonable suspicion can rest on the pooled knowledge of officers participating in a coordinated investigation (e.g., a task force using a secure radio channel), not only on the personal knowledge of the officer effectuating the stop.
Sentencing standards: United States v. Ayala-Lugo (1st Cir. 2021) (abuse-of-discretion review of sentences); United States v. Rivera-Rivera (1st Cir. 2025) and United States v. Montero-Montero (1st Cir. 2016) (plain-error framework).
Obstruction/perjury: United States v. Cohen (1st Cir. 2018) (perjury triggers § 3C1.1); United States v. Díaz (1st Cir. 2012) (elements of perjury); United States v. Dunnigan (U.S. 1993) (trial court should make findings supporting perjury-based enhancement).
Preservation/waiver: United States v. Pinkham (1st Cir. 2018) (review of preserved sentencing challenges); United States v. Rivera-Morales (1st Cir. 2020), United States v. Martínez-Mercado (1st Cir. 2025), and United States v. Cruz-Ramos (1st Cir. 2021) (need to argue plain error on appeal if unpreserved below, or the claim is waived).
Disparity: United States v. Casillas-Montero (1st Cir. 2025) and United States v. Coplin-Benjamin (1st Cir. 2023) (the “apples-to-apples” requirement under § 3553(a)(6)); United States v. Candelario-Ramos (1st Cir. 2022) and United States v. Wallace (1st Cir. 2009) (different sentencing judges can limit the relevance of co‑defendant comparisons).

Legal Reasoning

1) Reasonable Suspicion for the Vehicle Stop

The court applied the Terry/Kimball framework and assessed the totality of circumstances known collectively to the task force at the inception of the stop:

Months-long DTO investigation using a confidential informant, controlled fentanyl purchases, and extensive surveillance tied specific vehicles and individuals to two stash apartments eight miles apart: Unit 401 at 35 Audubon Road (Weymouth) and Unit 1321 at 333 Ricciuti Drive (Quincy).
Both apartments were leased by the same person (Lopes), Amado’s then-girlfriend, with indicia of fraud and implausible income, and the blue Jeep was listed on the Ricciuti lease. The team identified repeated “re‑up” patterns at the Audubon location, to the point of documenting precise parking/staging spots used for quick handoffs. State search warrants issued for both apartments on January 8.
On January 11, officers observed the blue Jeep with three men pull into the very “re‑up” spot beside Unit 401, with the front passenger (Fontes) behaving as a lookout. A woman (Vieira) exited the same side entrance used by a DTO member in prior visits, briefly interacted with the driver (Amado) at the Jeep, and returned inside without the green bag she had carried. Officers contemporaneously concluded that a re‑supply had occurred, and they immediately relayed this via secure radio to a designated vehicle stop team, which boxed in the Jeep nearby.

Amado argued that the officers did not recognize the Jeep’s occupants, that the complex was a large multi‑unit building, and that a brief bag exchange is ordinary behavior. The court rejected these points as a matter of law and fact:

Identity nonrecognition does not negate reasonable suspicion (Wardlow). What matters is behavior viewed in context.
Even in a large complex, the Jeep’s documented nexus to the specific unit (via lease, prior observations, and January 4 re‑up at the same physical spot), the issuance of a search warrant for that unit, and the observed lookout-and-bag exchange together supplied reasonable suspicion (Flores Perez; Sheckles as persuasive support).
The district court was entitled to credit the officers’ consistent accounts of the green bag and lookout behavior; trained officers’ interpretations warrant deference and need not be correct to be reasonable (Brown).
The stop team’s lack of firsthand knowledge is immaterial because the task force’s collective knowledge is imputed to the officers conducting the stop (Cruz-Rivera; Azor).

Accordingly, the denial of the suppression motion was affirmed on de novo review. Importantly, Amado had abandoned any appellate challenge to actions taken after the stop (ordering the occupants out, frisking them, and searching the car).

2) Obstruction of Justice (§ 3C1.1) for Perjury

The district court found that Amado perjured himself by falsely minimizing his connection to the Audubon stash apartment — the centerpiece of the DTO’s operation. The record showed:

GPS data placed Amado at the Audubon location almost daily, often for hours; his then‑girlfriend leased that unit at his direction.
Amado researched presses, cutting agents, and Glock firearms in October 2020 — items later recovered in the Audubon apartment — and his fingerprints were on cutting‑agent paraphernalia found there.
Phones linked to Amado revealed near‑daily drug sales communications, coordination with DTO members, and videos of Amado in the Audubon “mixing room,” including with two of the three pistols seized there.

Although Amado admitted ownership of narcotics seized from the Jeep and Ricciuti apartment and admitted posing with some firearms recovered at Audubon, he denied control or regular access to the Audubon apartment and its contraband. The court held it was not an abuse of discretion to find intentional, material falsehoods under oath — warranting the § 3C1.1 enhancement. Amado’s additional claim that the trial court failed to make the specific Dunnigan findings was forfeited because it was not preserved below.

3) Career-Offender Designation and Harmlessness

Amado argued for the first time on appeal that his 2017 and 2019 Massachusetts drug convictions should have counted as a single conviction (no “intervening arrest”), which would have defeated career-offender status. Because he did not raise this below and failed to argue plain error on appeal, the First Circuit deemed the claim waived. Moreover, any error was harmless: the district court’s independently calculated offense level (40) exceeded the career-offender level (37), and the criminal history category was VI in either event. Thus, the designation did not affect the operative advisory range.

4) Substantive Reasonableness and Co‑Defendant Disparity

Amado’s argument that his 384‑month sentence was disproportionate to co‑defendant Kevin Cardoso’s 188‑month sentence was not properly preserved in the district court and was waived on appeal. The First Circuit also explained why, even on the merits, the comparison faltered:

Different Guidelines exposure and criminal histories;
Cardoso pleaded guilty under a binding plea;
Sentencing by a different judge — a factor that reduces the relevance of cross‑defendant comparisons in assessing unwarranted disparity.

The court reiterated that § 3553(a)(6) comparisons must be “apples to apples.”

Impact and Implications

Fourth Amendment Practice

Collective knowledge in team operations: The decision robustly endorses the use of the collective knowledge doctrine for reasonable-suspicion stops in multi‑agency or task‑force settings. Officers on a stop team may rely on contemporaneous radioed observations of their surveillance colleagues.
Multi‑unit complexes: Presence at a large apartment complex is not inherently innocuous when officers can tie a vehicle and occupants to a specific unit known to be a stash location, especially where a search warrant has issued and officers observe conduct consistent with a prearranged re‑supply.
Behavior‑plus‑nexus: Brief exchanges that might otherwise appear routine (e.g., a short handoff of a bag) take on evidentiary significance when coupled with a documented DTO pattern (re‑ups, lookouts), a specific location nexus, and prior sightings of the same vehicle at the same spot.

Sentencing Practice

Preserve, or waive: The opinion is a strong reminder that sentencing objections must be preserved in the district court. On appeal, unpreserved claims must be framed and argued under the plain-error standard; failure to do so is waiver.
Dunnigan findings: To challenge § 3C1.1 on Dunnigan grounds (failure to make clear perjury findings), counsel should request specific findings at sentencing; otherwise, the argument risks forfeiture. The First Circuit will affirm if the record readily supports the perjury determination and the enhancement is otherwise justified.
Career offender harmlessness: Even if a career-offender designation is debatable, it may not warrant relief if it does not change the operative offense level or criminal history category governing the advisory range.
Disparity claims: Co‑defendant comparisons must grapple with material differences (plea posture, criminal history, role, Guidelines range, judge) to carry any persuasive weight under § 3553(a)(6).

Complex Concepts Simplified

Reasonable suspicion: A specific, articulable basis to believe “criminal activity may be afoot.” It is a lower threshold than probable cause and may rest on inferences drawn by experienced officers from the totality of the circumstances.
Terry stop (vehicle): A brief, investigatory stop of a vehicle based on reasonable suspicion. Courts ask: (1) Was the stop justified at its inception? (2) Were subsequent actions reasonably related to the basis for the stop?
Collective knowledge doctrine: When officers act as a coordinated team, the reasonable-suspicion analysis can consider the combined knowledge of participating officers (e.g., surveillance relayed over secure radio) rather than only what the stopping officer personally knew.
Stash house/re‑up dynamics: DTOs often keep bulk drugs and tools at a secure stash location. Dealers conduct short trips (“re‑ups”) to pick up supply, often with lookout behavior, quick hand‑offs, and repeated use of specific staging spots.
Obstruction-of-justice enhancement (§ 3C1.1): A two‑level Guidelines increase for obstructive conduct, including perjury at trial — knowingly giving false, material testimony. Dunnigan encourages specific findings on falsity, materiality, and willfulness.
Career offender (§ 4B1.1): A status enhancement for certain defendants with prior felony convictions for drug or violent offenses; it sets minimum offense levels and a criminal history category of VI. If the court’s independent offense level is higher, the higher level controls.
Intervening arrest (for counting prior sentences): Under § 4A1.2(a)(2), if there was an arrest for the first offense before committing the second, the sentences are always counted separately. Absent an intervening arrest, courts consider other factors to determine whether to count separately. Arguments on this must be preserved and, if raised for the first time on appeal, presented under plain-error review.
Plain error: A demanding standard for unpreserved claims on appeal. The error must be clear or obvious, affect substantial rights, and seriously affect the fairness, integrity, or public reputation of judicial proceedings.
Substantive reasonableness and disparity (§ 3553(a)(6)): Appellate review of whether a sentence is too long or too short given statutory factors. Co‑defendant disparity claims require “apples-to-apples” comparisons; differences in plea posture, criminal history, roles, and sentencing judges often justify differing sentences.

Conclusion

United States v. Amado fortifies several important doctrines in the First Circuit. On the Fourth Amendment front, it reaffirms that reasonable suspicion may be established through a task force’s collective knowledge in real time, especially when officers observe a patterned “re‑up” at a known stash apartment tied to the suspect vehicle and already subject to a search warrant. The decision also clarifies that presence at a multi‑unit complex is anything but neutral when the facts tightly connect the vehicle to a particular unit serving as a DTO hub.

On sentencing, the opinion underscores the importance of preservation and proper appellate framing (plain error, when required); illustrates how perjury grounded in demonstrably false minimization can support an obstruction enhancement; and reiterates the “apples-to-apples” requirement for disparity arguments. Finally, it highlights that some guideline label disputes (e.g., career offender) may be practically harmless when they do not alter the operative advisory range.

The net effect is a practical, prosecution- and law‑enforcement‑friendly blueprint for coordinated investigations of stash‑house DTOs, paired with a cautionary message to defendants: challenge specifics early and preserve them, because generalized or late‑breaking appellate claims will not carry the day. The First Circuit’s affirmance leaves in place a substantial sentence for a high-level recidivist trafficker and provides clear guidance on the evidentiary building blocks that will satisfy reasonable suspicion in analogous future cases.