USA v. Arnold et al

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
U NITED STATES OF A MERICA,
Plaintiff,
v. 	No. 4:25-cr-00259-P
D ANIEL ROLANDO SANCHEZ
E STRADA (09),
Defendant.
MEMORANDUM OPINION & ORDER
Before the Court is Defendant Daniel Rolando Sanchez Estrada’s
Motion to Suppress Evidence. ECF No. 202. Having reviewed the filings
and after oral arguments on the Motion at the February 12, 2026
hearing, the Court hereby DENIES the Motion.
BACKGROUND
On July 4, 2025, a group of individuals went to the Prairieland
Detention Center in Alvarado, Texas. ECF No. 127 at 1. After arriving,
individuals in the group began shooting fireworks and vandalizing
government 	property. 	ECF 	No. 	127 	at 	2. 	Allegedly, 	at 	least 	one
individual open-fired on the officers, striking an Alvarado police officer.
ECF No. 127 at 3. Shortly after the event, police arrested numerous
individuals, one of which being Defendant Maricela Rueda. ECF No. 127
at 3.
On or about July 5, 2025, law enforcement listened to a phone call
Defendant Rueda placed from Johnson County jail to her mother. ECF
No. 231 at 11.1 In the call, Rueda repeatedly told her mother to call
“Danny” because he knew everything and could explain it to her. ECF
1While the Court 	cites the Government’s response, 	the Court 	finds
pertinent to note that the phone call transcripts are in the record attached to
a different Motion. See ECF No. 201-1–201-4.
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No. 231 at 11. While Rueda told her mother “Danny” had nothing to “it,”
she also stated “Danny” would get in touch with “the community.” ECF
No. 231 at 11.
The next day around 10:55 a.m., Rueda called Sanchez from Johnson
County jail. ECF No. 231 at 11. During the call, Rueda informed
Sanchez of her car’s location and that her phone was in the car. ECF No.
231 at 11. She told Sanchez that her daughter knew the code to the
phone and to “do what you need to do.” ECF No. 231 at 11. Rueda
proceeded to tell Sanchez to tow her car and expressed concerns about
police potentially obtaining a warrant for her house to which Sanchez
replied that the house was “good.” ECF No. 231 at 12.
While Rueda was on the phone with Sanchez, FBI agents and TFOs
(collectively, “agents”) started watching Sanchez’s parents’ residence
which was associated with Sanchez. ECF No. 231 at 12; see ECF No. 202
at 5. Around 11:43 a.m., the agents saw Sanchez come out of the
residence and loaded three boxes, a white trash bag, an accordion-style
file folder, and an animal carrying container into a white, Chevrolet
Silverado pickup registered to Sanchez. ECF No. 231 at 12. The agents
followed Sanchez to an apartment where he dropped off one box at the
front door. ECF No. 231 at 13. The agents then followed Sanchez as he
left the apartment complex and radioed Denton police (DPD) to assist
by conducting a high risk felony traffic stop on Sanchez. ECF No. 231 at
13; ECF No. 202 at 5–6. The agents circled back to the apartment and
no package was seen at or near that apartment. ECF No. 231 at 14.
Following orders from the agents, DPD then stopped Sanchez’s
vehicle, arrested him, and searched his car. See ECF No. 202 at 6–8. The
reason for Sanchez’s warrantless arrest was not communicated to DPD.
See ECF No. 202 6–9; see also ECF No. 231 at 13. DPD seemingly
believed that they needed independent probable cause or reasonable
suspicion to arrest Sanchez. See ECF No. 202 at 7–10. DPD then
scrambled to piece together a pretextual stop. See id.
LEGAL STANDARD
The Fourth Amendment guarantees individuals the right “to be
secure 	in 	their 	persons, 	houses, 	papers, 	and 	effects, 	against
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unreasonable 	searches 	and 	seizures.” 	U.S. 	Const. 	amend. 	IV. 	A
warrantless arrest and search is “presumptively unreasonable unless
the circumstances fall under an exception to the Fourth Amendment's
warrant requirement.” United States v. Clayton, 98 F.4th 256, 261 (5th
Cir. 2024); United States v. Thomas, 997 F.3d 603, 609 (5th Cir. 2021).
An exception to a warrantless arrest and warrantless search is probable
cause. Clayton, 98 F.4th at 263; United States v. Robles, No. 98-10110,
1999 U.S. App. LEXIS 40013, at *42 (5th Cir. 1999).
Probable cause is determined by the totality of the circumstances.
Clayton, 98 F.4th at 263. The probable cause inquiry for a warrantless
search asks whether “there is a fair probability that contraband or
evidence of a crime will be found in a particular place.” Illinois v. Gates,
462 U.S. 213, 238 (1983). Probable cause exists for a warrantless arrest
“when the totality of facts and circumstances within a police officer’s
knowledge at the moment of arrest are sufficient for a reasonable person
to conclude that the suspect had committed, or was in the process of
committing, an offense.” Robles, 1999 U.S. App. LEXIS 40013, at *42.
The Supreme Court has “instructed that we must be cautious about
second-guessing a police officer’s assessment, ‘made on the scene, of the
danger presented by a particular situation.’” Velasquez v. Audirsch, 574
Fed. Appx. 476, 482 (5th Cir. 2014) (quoting Ryburn v. Huff, 565 U.S.
469, 476–77 (2012)).
ANALYSIS
The Court must answer two questions regarding this Motion. First
whether the arresting officers needed independent probable cause to
make a warrantless arrest of Sanchez and search his car. If not, second,
whether the agents 	had probable cause that was imputed 	to 	the
arresting officers.
I. 	The knowledge of the agents is imputed to the arresting
officers under the collective knowledge doctrine.
“Under the collective knowledge doctrine, it is not necessary for the
arresting officer to know all of the facts amounting to probable cause, as
long as there is some degree of communication between the arresting
officer and an officer who has knowledge of all the necessary facts.”
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United States v. Willis, 304 Fed. Appx. 256, 258 (5th Cir. 2008) (quoting
United States v. Ibarra, 493 F.3d 526, 530 (5th Cir. 2007)). In fact, the
arresting officer need not possess personal knowledge of the probable
cause at all. See Ibarra, 493 F.3d at 530. This is because the actual
knowledge of probable cause is “imputed to the arresting officers.”
Willis, 304 Fed. Appx. at 258. The collective knowledge doctrine “is a
matter of 	common 	sense: 	it minimizes 	the 	volume 	of 	information
concerning suspects that must be transmitted to other jurisdictions and
enables 	police 	in 	one 	jurisdiction 	to 	act 	promptly 	in 	reliance 	on
information from another jurisdiction.” United States v. Hensley, 469
U.S. 221, 231 (1985).
In Willis, a detective with the Baton Rouge Police Department
(“BRPD”) and 	an 	agent 	of 	the 	Drug 	Enforcement 	Administration
(“DEA”) asked the BRPD for help finding and arresting the defendant.
304 Fed. Appx. at 257. “The district court found that the police did not
have probable cause to arrest Willis, because [the police] lacked personal
knowledge of the probable cause.” Id. at 258. However, the United States
Court of Appeals for the Fifth Circuit reversed, holding that the police
had probable cause under the “collective knowledge doctrine.” Id. The
Fifth Circuit continued, stating even though the orders to arrest came
through a dispatcher and did not specify the conduct that led to the arrest
order, the collective knowledge doctrine applies.” Id. (emphasis added).
Here, the arresting officers lacked personal knowledge of the facts
giving rise to probable cause for an arrest of Sanchez and the subsequent
search of his vehicle. But, under the collective knowledge doctrine, the
knowledge of the agents are imputed to the arresting officers. Therefore,
the arresting officers did not need independent probable cause to stop
and arrest Sanchez or to search his car. While the actions of the
arresting officers were dubious, they do not control the analysis. The
decisive inquiry before the Court then is whether, at the time of
warrantless arrest and search, probable cause existed for the agents.
II. The agents had probable cause for a warrantless arrest and
subsequent search of the vehicle.
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As aforementioned, probable cause is determined by the totality of
the circumstances. Clayton, 98 F.4th at 263. Viewing the totality of the
circumstances, probable cause existed at the time of Sanchez’s arrest
and search of his car. Rueda’s phone call to her mother stated that
Sanchez had knowledge of the events that occurred and could get in
touch with “the community.” This call came one day after the events at
the Prairieland ICE facility where an Alvarado police officer was shot
and injured. In the phone call to Sanchez on July 6, Rueda talked about
police getting warrants to search houses to which Sanchez said that the
house was “good;” she told Sanchez to tow her car; and informed Sanchez
to “do what [he] need[s] to do.”
Additionally, two days after the events at the Prairieland Detention
Center, the agents witnessed Sanchez load three boxes, a white trash
bag, and an accordion-style file folder into his truck and offload at least
one box onto another’s porch. After Sanchez made the drop of one of the
boxes, the box was quickly picked up by someone in the short time that
the agents saw the drop then circled back.
Taken together, a reasonable person would conclude that Sanchez
was in the process of concealing documents with the intent to impair
their availability and use in an official proceeding, which is an offense
under 18 U.S.C. § 1512(c)(1) and (k). Thus, the agents had probable
cause to arrest Sanchez. Additionally, there was a fair probability that
evidence of a crime would be found in Sanchez’s truck, supplying the
agents with probable cause for the search of his vehicle. Because the
actual knowledge of the facts giving rise to the probable cause is imputed
to the arresting officers, the warrantless arrest of Sanchez and search of
his car was supported by probable cause and did not violate Sanchez’s
Fourth Amendment rights.
CONCLUSION
Accordingly, the Motion to Suppress is DENIED.
SO ORDERED on this 16th day of February 2026.
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
REGINALEA KEMP ,
Plaintiff,
v. 	No. 4:23-cv-00841-P
REGIONS BANK ET AL .,
Defendants.
ORDER
Before the Court is Plaintiff’s Unopposed Motion for Leave to File
Second Amended Complaint. ECF No. 18. Having considered the Motion
and applicable docket entries, the Court GRANTS the Motion.
SO ORDERED on this 18th day of September 2023.
______________________________________________
Mark T. Pittman
UNITED STATES DISTRICT JUDGE
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