Reinforcement of Fourth Amendment Standing and the Scope of the Automobile and Inevitable Discovery Exceptions

Introduction

United States v. Grayson Zachary Eagan is an appeal decided by the United States Court of Appeals for the Eleventh Circuit on April 16, 2025. The defendant, Grayson Eagan, pleaded guilty—unconditionally—to federal counts of conspiracy to distribute methamphetamine and heroin, possession with intent to distribute those drugs, possession of a firearm in furtherance of a drug‐trafficking offense, and possession of a firearm as a felon. Before sentencing, he moved to suppress evidence found in his vehicle, arguing (1) that he had Fourth Amendment standing to challenge the search, (2) that the automobile exception did not apply, and (3) that deputies would not inevitably have discovered the evidence under the “inventory” exception. The district court denied suppression; Eagan appealed, and this opinion affirms the denial on all three grounds.

Summary of the Judgment

The Eleventh Circuit affirmed. It held:

1. Standing: Eagan’s motion to suppress contained only conclusory references to “his car” and failed to allege any fact (ownership, possessory rights, or right to exclude) supporting a reasonable expectation of privacy.
2. Automobile Exception: Eagan’s vehicle was readily mobile and there was probable cause to search it—he led deputies on a multi-state, high-speed chase, during which occupants discarded suspected contraband.
3. Inevitable Discovery: Under Baldwin County Sheriff’s Office policy, the impounded vehicle would have been inventoried and its contents discovered absent any Fourth Amendment violation. Eagan’s arguments that the impoundment was pretextual or jurisdictionally flawed failed.

Analysis

Precedents Cited

• Unconditional Guilty Pleas and Challenge Preservation:
  • United States v. Pierre, 120 F.3d 1153 (11th Cir. 1997): A plea accepted under a mistaken preservation belief can be vacated, but only if the record shows the plea was not knowing and voluntary.
  • United States v. Sanfilippo, 91 F.4th 1380 (11th Cir. 2024): A belated challenge to plea validity is forfeited if not raised in the opening brief.
  • United States v. Chalker, 966 F.3d 1177 (11th Cir. 2020): Issues cannot be raised for the first time in a reply brief.
• Standard of Review & Multiple Grounds:
  • United States v. Campbell, 26 F.4th 860 (11th Cir. 2022 en banc): Denials of suppression motions present mixed fact–law questions; we accept factual findings unless clearly erroneous and review legal conclusions de novo.
  • Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014): When a judgment rests on multiple independent grounds, an appellant must show all are incorrect.
• Fourth Amendment Standing:
  • United States v. Miller, 821 F.2d 546 (11th Cir. 1987) & United States v. Ross, 963 F.3d 1056 (11th Cir. 2020): Standing requires a reasonable expectation of privacy—both subjective and one that society deems reasonable.
  • United States v. Ramos, 12 F.3d 1019 (11th Cir. 1994): The defendant bears the burden to plead facts supporting that expectation.
  • United States v. Sneed, 732 F.2d 886 (11th Cir. 1984): If standing is contested, a defendant must amend the motion to suppress to include supporting facts.
  • United States v. Cooper, 203 F.3d 1279 (11th Cir. 2000): Conclusory statements without supporting facts (e.g., “the hotel room was ours”) are insufficient.
• Automobile Exception:
  • United States v. Lanzon, 639 F.3d 1293 (11th Cir. 2011): Warrantless search allowed if the vehicle is readily mobile and there is probable cause.
  • United States v. Morley, 99 F.4th 1328 (11th Cir. 2024): All operational vehicles are inherently readily mobile.
  • United States v. Watts, 329 F.3d 1282 (11th Cir. 2003): No additional exigency beyond inherent mobility is required.
  • United States v. Lindsey, 482 F.3d 1285 (11th Cir. 2007): Probable cause is assessed under the totality of the circumstances.
• Inevitable Discovery Exception:
  • United States v. Watkins, 13 F.4th 1202 (11th Cir. 2021): Evidence admissible if the government proves by a preponderance that it would have been discovered lawfully anyway.
  • United States v. Rhind, 289 F.3d 690 (11th Cir. 2002): Inventory searches under standardized police procedures qualify as lawful means.
  • Sammons v. Taylor, 967 F.2d 1533 (11th Cir. 1992): Impoundment is permitted if based on routine criteria, not pretext for searching.

Legal Reasoning

1. Standing: The court held that Eagan’s suppression motion failed the Ramos burden. He never alleged ownership, a possessory interest, or a right to exclude others. His repeated references to “Eagan’s car” were conclusory labels, akin to the “offhanded references” condemned in Cooper. When the government challenged standing, Eagan did not amend his motion to plead supporting facts. Under Sneed, his motion thus failed at the threshold.

2. Automobile Exception: Eagan did not dispute probable cause—his high‐speed, multi‐state flight, officer observations of objects being tossed, and traffic violations more than suffice. His crash did not negate ready mobility: an automobile need only be “operational” or reasonably capable of functioning. Watts confirms no further exigency requirement is necessary.

3. Inevitable Discovery: BCSO policy mandated impoundment of vehicles used in felonies and routine inventory searches thereafter. The record shows deputies would have “actively pursued” an inventory consistent with their standard operating procedure. Eagan’s claim of pretext fails when undisputed policy, along with the private‐property tow and pre-existing leads, establish by a preponderance that the contraband would have been discovered anyway.

Impact

This decision underscores three key lessons for practitioners and lower courts:

1. Rigorous Pleading for Standing: Defendants must plead concrete facts—ownership, control, or exclusion rights—to establish Fourth Amendment standing. Bare labels or “my car” language will not suffice.
2. Enduring Strength of the Automobile Exception: Crash scenes and stationary cars do not defeat ready mobility so long as the vehicle remains operational or reasonably appears capable of functioning.
3. Broad Application of Inevitable Discovery: Standard impoundment and inventory procedures continue to provide a robust means to admit evidence even if an initial search might be constitutionally suspect.

Complex Concepts Simplified

• Fourth Amendment Standing: To challenge a search, you must show you had a real, private interest in the place or item searched—simply being near it or saying “it’s mine” is not enough.
• Automobile Exception: Police can search a car without a warrant if it can move and there’s reason to believe it contains illegal items.
• Inevitable Discovery: Even if police break the rules, evidence isn’t thrown out if they can prove they would have found it lawfully anyhow.
• Mixed Questions of Fact and Law: Appeals courts accept the trial court’s factual findings unless they’re clearly wrong, but they re-decide the legal conclusions from scratch.

Conclusion

United States v. Eagan reaffirms fundamental Fourth Amendment doctrines—defendants’ burden to plead standing, the breadth of the automobile exception, and the reach of the inevitable discovery rule. By insisting on clear factual allegations and upholding standardized police procedures, the Eleventh Circuit fortifies law enforcement’s ability to secure and process vehicles while preserving constitutional safeguards. Future litigants will face a high bar in alleging standing and a reality that routine impoundment policies can render suppression efforts futile.