Mike Campbell and his best friend, John Wright, were driving north on I-95 returning from spring break in Florida, when they were stopped by members of a drug task force made up of Volousia County Sheriff officers and federal drug enforcement agents. The agents requested permission to search the car.When Campbell refused consent, the agents brought in a drug dog that alerted to the trunk of the car. The agents then claimed that the dog's actions gave them probable cause to search the trunk and gave Campbell the choice of either opening the trunk or waiting until the agents obtained a search warrant.After Campbell opened the trunk, the agents found two kilograms of cocaine in a brown paper bag. Campbell and Wright were arrested and charged with possession with intent to distribute cocaine. Prior to trial they filed a motion to suppress the cocaine claiming that it was the fruit of an unreasonable search and seizure.

The agents claimed they stopped the Campbell car because Campbell was following the car in front of him too closely and because the following facts fit a drug courier profile used by the Volusia County Sheriff officers:

2. The car was a large late model;
4. The car had out-of-state tags;
6. The car was being driven cautiously at the speed limit;
8. The car was being driven on a known drug corridor, I-95;
10. There were two passengers in the car;
12. The passengers were in their twenties;
14. The car was being driven in the early evening; and
16. The passengers were dressed casually.

Although not listed by the agents, Campbell and Wright believe the real reason they were stopped is because they are Afro-Americans, or DWB (Driving While Black).

Your directions: Mrs. Mom Campbell has hired our law office, Money Is Always the Cure (MATC) to represent her son who had been arrested for possession of cocaine on October 16^th of this year. On October 19^th this attorney (Yours Truly), met with Mrs. Campbell and her son Michael where the Mother asked whether the cocaine could be suppressed from evidence. You will be drafting a letter to her for your supervising attorney's signature, limiting your discussion and research to the facts provided above and to the federal law as of the date of this letter (December 2015), to be used solely for the benefit of Mrs. Campbell and her son.

In your letter, consider the following explanations of discussion:

2. Explain the government's first argument, e.g. Fourth Amendment; reasonable search and United States v. Smith, 799 F.2d 704, 712 (11^th Cir. 1986);
4. Explain Smith; and
6. Explain the government's second argument using Whren v. United States, 517 U.S. 806, 818 (1996).