U.S. v. Glenn – Case Brief Summary (Federal Court)

In U.S. v. Glenn, 152 F.3d 1047 (8th Cir.1998), a lawful stop of a vehicle occurred, pursuant to which the officer intended to access Glenn's driving record on the computer.

The officer asked Glenn to follow him to his patrol car while he accessed the records, and when they reached the car, the officer unlawfully searched Glenn, which revealed a weapon.

Glenn was then arrested, after which the officer ran a computer check and learned Glenn did not have a valid license.

The court concluded that inevitable discovery applied because when the search took place, the officer was in the process of identifying Glenn as a permissible part of the initial traffic stop, and would have completed the license check even if he had found no weapon.

That license check would have revealed that Glenn was operating a vehicle without a driver's license, subjecting him to arrest. Id. at 1050.