USA v. Olalde-Nieves

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UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
United States of America,
Plaintiff,
v.
Raymundo Olalde-Nieves
Defendant.
Case No. 25-cr-0038 (SRN/DLM)
REPORT AND
RECOMMENDATION
This matter is before the Court on Defendant Raymundo Olalde-Nieves’s Motion to
Suppress Evidence (Doc 27). The case has been referred to the undersigned United States
Magistrate Judge for a Report and Recommendation pursuant to 28 U.S.C. § 636 and
District of Minnesota Local Rule 72.1.
The Court held an evidentiary hearing on Mr. Olalde-Nieve’s motion on September
9, 2025. (Docs. 35 (Minutes), 37 (Motions Hearing Transcript, hereinafter referred to as
“Tr.”)) Thomas Hollenhorst, Esq., appeared on behalf of the United States of America (“the
government”). Wyatt Arneson, Esq., appeared on behalf of Mr. Olalde-Nieves, who was
present at the hearing with an interpreter. The briefing on this matter concluded on October
28, 2025. For the reasons explained below, the Court recommends that Mr. Olalde-Nieves’s
Motion to Suppress Evidence (Doc. 27) be denied.
BACKGROUND
On February 12, 2025, Mr. Olalde-Nieves was charged by indictment with one count
of Conspiracy to Distribute Methamphetamine, in violation of 18 U.S.C. §§ 841(a)(1),
841(b)(1)(A), and 846, and one count of Possession with the Intent to Distribute
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Methamphetamine, in violation of 18 U.S.C. §§ 841(a)(1) and 841(b)(1)(A). (See generally
Doc. 1.)
Mr. Olalde-Nieves’s motion to suppress centers around a vehicle search, during
which law enforcement found the drugs at the heart of his charged offenses. He asserts that
the warrantless search of the vehicle violated his constitutional rights under the Fourth
Amendment. (See generally Docs. 27, 40.) Specifically, he argues that a traffic stop of the
vehicle—perhaps valid at the outset—was unlawfully extended such that any subsequent
search was improper; that a drug dog sniff of the vehicle violated the Fourth Amendment;
and that no exception to the warrant requirement authorized the seizure or search of the
vehicle. (See generally Doc. 40.) Ultimately, he argues, these alleged constitutional
violations merit suppression of all seized evidence. (Id.)
The Court held an evidentiary hearing on Mr. Olalde-Nieves’s motion to suppress.
(Doc. 35 (Minutes).) At that hearing, the Court heard testimony from Special Agent Connie
Gerten of the Drug Enforcement Agency (“DEA”), as well as from Minnesota State
Troopers Anthony Mains and Patrick Beuning. The government offered and the Court
received Government Exhibit 1, Trooper Mains’s body-worn camera (“BWC”) video;
Government Exhibit 2, Trooper Beuning’s BWC video; Government Exhibit 3, Canine
Certifications for “Frizko”; Government Exhibit 4, Minnesota State Patrol Inventory
Policy; and Government Exhibit 5, Minnesota State Patrol Tow Report. (Id.)
The evidence presented at the motions hearing established the following. On August
22, 2024, DEA agents planned to conduct a controlled methamphetamine buy as part of an
ongoing investigation into a drug trafficking scheme. (Tr. at 11.) Over the course of this
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years-long investigation, law enforcement had identified an individual named Mr. Sergio
Marin-Gamino, who served as a drug trafficking intermediary between a Mexico-based
supply source and the Minnesota market. (See generally id.) Law enforcement officers had
been surveilling Mr. Marin-Gamino since June 2024. (Tr. at 11.) In August 2024, a
confidential source (“CS”) working with the DEA agreed purchase 56 pounds of
methamphetamine from Mr. Marin-Gamino. (Tr. at 14.) Because the CS and Mr. Marin-
Gamino had only previously exchanged one pound of methamphetamine, they agreed to
split this much larger transaction into two exchanges. (Tr. at 12, 14.) The initial sale of two
pounds of methamphetamine occurred on August 13, 2024, under government surveillance.
(Tr. at 14, 16.) During that transaction, Mr. Marin-Gamino and the CS discussed
exchanging the remaining 54 pounds of methamphetamine at a location in Brooklyn Park
or Brooklyn Center. (Tr. at 16.)
On August 22, 2024, Mr. Marin-Gamino texted the CS the location for the next sale:
a parking lot on the 8500 block of Zane Avenue North, Brooklyn Park, Minnesota. (Tr. at
19.) Again under government surveillance, Mr. Marin-Gamino left his residence just after
one o’clock in the afternoon on August 22, and drove toward the agreed-upon Brooklyn
Park location. (Tr. at 20.) As Mr. Marin-Gamino approached the Zane Avenue parking lot,
he began to drive erratically, which law enforcement believed to be a countersurveillance
technique. (Tr. at 20.) Around this time, Mr. Marin-Gamino communicated with the CS
that the plan had changed, and that the CS would be meeting with a third-party—without
Mr. Marin-Gamino. (Tr. at 20.) Mr. Marin-Gamino referred to “moscas” (flies in Spanish),
which Agent Gerten interpreted to mean that Mr. Marin-Gamino understood he was under
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surveillance and did not want to bring law enforcement to the drug-deal location. (Tr. at
20.) Due to this change, the CS contacted the Mexican source, who confirmed the changed
plan. (Tr. at 20.)
About an hour later, Mr. Marin-Gamino informed the CS that the CS would be
meeting with an unidentified person driving a gray Chevy Malibu at the same Zane Avenue
parking lot as originally planned. (Tr. at 21.) Within ten minutes, law enforcement officers
observed a gray Chevy Malibu drive into the Zane Avenue parking lot. (Tr. at 21.) Mr.
Olalde-Nieves was driving the vehicle. (Tr. at 21.) He parked, exited, went to the Chevy’s
trunk, opened it, returned to the driver’s seat, then walked to the building next to the lot
and returned to the car, where he again opened and closed the vehicle trunk. (Tr. at 21.) At
this point, the Mexican source relayed to the CS that “the guy had the merchandise,” which
law enforcement understood as coded language for methamphetamine. (Tr. at 21.) Mr.
Marin-Gamino also communicated with the CS and informed the CS that the “guy at the
location was waiting for him.” (Tr. at 22.)
A marked Minneapolis Police Department squad car then entered the Zane Avenue
parking lot where Mr. Olalde-Nieves was located, as part of a planned effort to flush him
out of the lot so law enforcement could initiate a traffic stop. (Tr. at 22-23.) The CS
participated in this plan too, telling Mr. Marin-Gamino that he did not want to continue
with the exchange in the Zane Avenue lot given the police presence. (Tr. at 23).
After some negotiation, Mr. Marin-Gamino agreed to a new location: a grocery store
parking lot located a bit further down Zane Avenue. (Tr. at 24.) Law enforcement officers
then observed Mr. Olalde-Nieves drive out of the parking lot in the direction of the grocery
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store, confirming agents’ suspicion that he had just communicated with someone about the
new meeting location. (Tr. at 23-24).
At this point, Agent Gerten instructed Trooper Mains via radio to make a pretextual
traffic stop. (Tr. at 24-25; 33-34.) According to Agent Gerten’s testimony, even before the
traffic stop, law enforcement concluded that probable cause existed to arrest Mr. Olalde-
Nieves and search his vehicle without a warrant. (Tr. at 25-26.) In Agent Gerten’s view, the
traffic stop was meant to protect the CS and ensure the secrecy of the ongoing investigation
but was not necessary to satisfy a finding of probable cause. (Tr. at 26.) At Agent Gerten’s
request, Trooper Mains followed Mr. Olalde-Nieves, whom Trooper Mains observed
driving without a seatbelt in violation of Minnesota law. (Tr. at 35.) Before Trooper Mains
activated his squad lights, Mr. Olalde-Nieves turned into a school parking lot. (Tr. at 41.)
Trooper Mains followed, activated his lights, and then exited his squad car and approached
the driver’s side window of Mr. Olalde-Nieves’s vehicle. (Tr. at 38, 42; Ex. 1 at 1:32-37.)
Trooper Mains testified that as he approached the vehicle, he observed that Mr.
Olalde-Nieves was sweating and appeared anxious, describing him as “probably honestly
the most nervous I’ve ever seen someone.” (Tr. at 39.) During the stop, Trooper Mains told
Mr. Olalde-Nieves to “calm down” because he was “shaking like a leaf.” (Ex. 1 at 02:00.)
Trooper Mains asked Mr. Olalde-Nieves for his driver’s license and insurance. (Ex. 1 at
1:44-2:20.) Mr. Olalde-Nieves provided his license but said that the car was his brother’s
and proceeded to search for insurance unsuccessfully. (Tr. at 45; Ex. 1 at 2:12.) When
Trooper Mains asked Mr. Olalde-Nieves where he was coming from, Mr. Olalde-Nieves
responded that he was coming from work and going to visit his “compadre” across the
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street. (Tr. at 41; Ex. 1 at 2:26-2:38.) When Trooper Mains pressed Mr. Olalde-Nieves about
why he had turned into a school parking lot, Mr. Olalde-Nieves represented that he was in
fact going to Alphonsa Church—on the other side of Brooklyn Park—to collect his son,
who he had forgotten to pick up. (Tr. at 43; Ex. 1 at 2:45-2:50)
Unable to locate insurance, Mr. Olalde-Nieves represented to Trooper Mains that he
would call his brother. (Ex. 1 at 4:03.) Trooper Mains then told Mr. Olalde-Nieves that he
would not give him a seatbelt ticket. (Tr. at 49; Ex. 1 at 4:54.) Returning to his squad car,
Trooper Mains ran Mr. Olalde-Nieves’s drivers license, which indicted that the license was
revoked and the car was not registered in his name. (Tr. at 45; Ex. 1 at 6:20-6:50.) With
Mr. Olalde-Nieves still unable to locate insurance, Trooper Mains told him that he could
not leave with the vehicle, since he had no valid license or insurance. (Tr. at 46-47; Ex. 1
at 17:10.) Trooper Mains then questioned Mr. Olalde-Nieves about any contraband in the
car and asked if he could search the car, but Mr. Olalde-Nieves declined because the vehicle
was not his. (Ex. 1 at 20:00-20:38.) Trooper Mains then placed Mr. Olalde-Nieves, who
was standing in the street next to the vehicle,1 in the back of his squad car. (21:30-21:49.)
Next, Trooper Beuning, who arrived on the scene soon after Trooper Mains, used
his canine partner Frizko to conduct a drug sniff of the Chevy Malibu. (Tr. at 67; Ex. 2 at
23:54-25:06.) Frizko is trained to “alert” to the odor of narcotics and “indicate,” by sitting
or lying down, upon locating the source of the odor. (Tr. at 72.) Trooper Beuning walked
1 At an unidentified point during the stop, after Trooper Mains had returned to his squad
car to run the license, Mr. Olalde-Nieves exited the Chevy Malibu to speak with Trooper
Mains next to the squad car.
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Frizko to the Chevy Malibu where Frizko soon after jumped up and put his head into the
open passenger-side window. (Tr. at 77; Ex. 2 at 24:07-24:10.) According to his testimony,
Trooper Beuning observed Frizko alert to the smell of narcotics before jumping and poking
his head through the vehicle’s open window. (Tr. at 78-79, 81.) Frizko then circled the
Malibu several times before indicating by sitting near the passenger side door. (Tr. at 76;
Ex. 2 at 25:00.) Troopers Beuning and Mains then searched the Chevy Malibu and
uncovered several 5-gallon buckets in the trunk, each filled with plastic bags of white
powder. (Ex. 1 at 26:30-27:38.) Trooper Mains returned to the squad vehicle and informed
Mr. Olalde-Nieves that he was under arrest and placed him in handcuffs. (Ex. 1 at 27:46-
28:40.) Ultimately, law enforcement seized 54 pounds of methamphetamine from the
vehicle’s trunk. (Doc. 37 at 10, 81; Ex. 1 at 27:35.)
ANALYSIS
Mr. Olalde-Nieves makes several arguments in support of suppressing the seized
evidence. He argues that law enforcement unreasonably prolonged what may have been a
valid traffic stop beyond the time necessary to investigate his alleged traffic violations, an
unconstitutional seizure that should result in the exclusion of any subsequently-discovered
evidence. Additionally, Mr. Olalde-Nieves argues that the drug dog sniff violated his Fourth
Amendment rights because, in his view, law enforcement “directed” Frizko to search inside
his vehicle, and thus, Frizko did not validly indicate to the presence of drugs. He also
asserts that law enforcement’s warrantless search of the passenger compartment of his
vehicle after he was handcuffed in the back of Trooper Mains’s squad vehicle violates
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Arizona v. Gant’s2 limitations on warrantless vehicle searches. (Doc. 40 at 4.) Finally, he
argues that because the Chevy Malibu was parked in an empty lot and therefore did not
need to be towed, law enforcement would not have necessarily inventoried the vehicle such
that the “inevitable-discovery doctrine” could save the evidence from suppression.
The government, for its part, responds that probable cause existed before the
pretextual stop and only grew stronger over the course of the afternoon. First, the
government recounts the in-depth nature of the investigation to argue that probable cause
existed before the pretextual traffic stop. Next, the government represents that the lawfully
extended pretextual stop only provided additional facts to support of a finding of probable
cause. As for the drug dog sniff, the government contends that Frizko alerted to the
presence of drugs immediately, and that his alert independently established probable cause
to search the vehicle. Finally, the government contends that Mr. Olalde-Nieves’s motion
should be denied because the Minnesota State Patrol’s tow policy dictates that the Chevy
Malibu would have been towed and inventoried in any event, such that law enforcement
would have found the methamphetamine pursuant to the doctrine of inevitable discovery.
I. PROBABLE CAUSE EXISTED TO SEARCH THE VEHICLE BEFORE
THE STOP OCCURRED.
The Court begins its analysis with the events preceding the traffic stop itself. The
Fourth Amendment guarantees “[t]he right of the people to be secure in their persons,
houses, papers, and effects, against unreasonable searches and seizures[.]” U.S. Const.
amend. IV. While warrantless seizures are unreasonable per se, United States v. Madrid,
2Arizona v. Gant, 556 U.S. 332 (2009).
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152 F.3d 1034, 1037 (8th Cir. 1998), it is well-established that law enforcement may search
a vehicle incident to a valid arrest without a warrant if they have probable cause to believe
it contains evidence of criminal activity. Arizona v. Gant, 556 U.S. 332, 343 (2009); United
States v. Mims, 122 F.4th 1021, 1032 (8th Cir. 2024); United States v. Beard, 708 F.3d 1062,
1065 (8th Cir. 2013). “[P]robable cause is a fluid concept—turning on the assessment of
probabilities in particular factual contexts—not readily, or even usefully, reduced to a neat
set of legal rules.” Illinois v. Gates, 462 U.S. 312, 232 (1983). The probable cause inquiry
looks at the totality of the circumstances, and includes law enforcement’s reliance upon
their own experiences and training when assessing the existence of probable cause. United
States v. Robinson, 670 F.3d 874, 876 (8th Cir. 2012). Ultimately, probable cause is not a
high bar to meet. Kaley v. United States, 571 U.S. 320, 338 (2014).
Preexisting information provided through a reliable informant and investigation
may be sufficient to establish probable cause to conduct a warrantless search of a vehicle.
United States v. Edwards, 891 F.3d 708, 712 (8th Cir. 2018). The fact that a defendant has
not been identified or named as a subject of interest in an ongoing investigation does not
vitiate a finding of probable cause. United States v. Williams, 616 F.3d 760, 765
(“[p]robable cause does not require certainty regarding [the Defendant’s] identity.”). What
is required is that officers could reasonably identify Mr. Olalde-Nieves as “participating in
a drug transaction and involved in the greater conspiracy at play,” based on circumstances
of the investigation, physical surveillance, and intercepted wiretap calls that point to his
participation in a drug conspiracy. Id. Finally, probable cause need not be based solely on
the observations of a single officer on the scene, but “may be based on the collective
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knowledge of all law enforcement officers involved in an investigation . . . if there is some
degree of communication.” Edwards, 891 F.3d at 711-712 (quoting United States v. Horne,
4 F.3d 579, 585 (8th Cir. 1993)).
The evidentiary record here shows that probable cause to search the Chevy Malibu
without a warrant existed before the pretextual stop. At the time of the traffic stop, law
enforcement’s investigation was two years in the making, and Mr. Marin-Gamino had been
under surveillance for several months. Through the CS, law enforcement had already
completed two controlled buys with Mr. Marin-Gamino, and law enforcement had no
reason to doubt Mr. Marin-Gamino’s consistency. On August 22, still under law
enforcement surveillance, Mr. Marin-Gamino told the CS that a gray Chevy Malibu
(without him) would arrive loaded with methamphetamine at a designated parking lot.
Minutes later a gray Chevy Malibu drove into the designated parking lot. And after the CS
and Mr. Marin-Gamino changed the meet-up location, law enforcement observed the driver
of the Chevy Malibu, later identified as Mr. Olalde-Nieves, receive a phone call and then
drive in the direction of the new location. Given the specific and in-depth collective
knowledge of law enforcement, and Mr. Olalde-Nieves’s conduct consistent with that
information, the Court finds that law enforcement had probable cause to search the Chevy
Malibu before the traffic stop occurred.
II. THE TRAFFIC STOP PROVIDED ADDITIONAL PROBABLE CAUSE.
The Court next considers the traffic stop itself, both in terms of its scope an
information gleaned during that stop. A traffic stop is a seizure under the Fourth
Amendment. United States v. Hanel, 993 F.3d 540, 543 (8th Cir. 2021). As such, it must be
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supported by reasonable suspicion or probable cause—but even a minor traffic violation
provides that support. Id; United States v. Bloomfield, 40 F.3d 910, 915 (8th Cir. 1994). As
long as the traffic stop is supported by probable cause or reasonable suspicion, any
pretextual purpose or “ulterior motivation on the officer’s part is irrelevant.” United States
v. McLemore, 887 F.3d 861, 864 (8th Cir. 2018) (quoting United States v. Fuehrer, 844 F.3d
767, 772 (8th Cir. 2016)). But a traffic stop may become unlawful if prolonged “beyond
the time reasonably required to complete the mission of issuing a warning ticket.”
Rodriguez v. United States, 575 U.S. 348, 349 (2015) (cleaned up). Accordingly, a traffic
stop may be extended only where an officer develops a reasonably articulable suspicion
that criminal activity is afoot over the course of the stop. United States v. Callison, 2 F.4th
1128, 1132 (8th Cir. 2021). Factors that contribute to a reasonable suspicion of criminal
activity include unusual driving behavior; attempts to evade law enforcement; indirect or
incomplete answers to officer questioning; nervousness; and inconsistences and
implausibility’s in the responses to law enforcements questions about travel plans. Id.
Here, Trooper Mains lawfully initiated and extended the traffic stop. At the
evidentiary hearing, Trooper Mains testified that he observed Mr. Olalde-Nieves driving
without a seatbelt. Because nothing in the record contradicts this point, and because driving
a motor vehicle without a seatbelt violates Minnesota state law, the Court concludes that
Trooper Mains had probable cause to initiate the traffic stop, separate and apart from the
Court’s earlier probable cause finding based on the drug investigation.
Law enforcement was also justified in extending the stop beyond its superficial
purpose. Again, beyond the backdrop of a larger drug investigation, a constellation of
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factors supports reasonable suspicion here. First, Trooper Mains testified to the
Defendant’s singular nervousness, even stating that Mr. Olalde-Nieves was “one of the
most nervous” people that Trooper Mains had arrested in his experience of thousands of
stops. Trooper Mains also testified that Mr. Olalde-Nieves’s shifting and odd answers to
routine questioning—for instance that he was visiting his compadre, and then quickly
noting he was headed in the opposite direction because he had forgotten to pick up his son
from Alphonsa Church—spurred his suspicion. Trooper Mains also testified to his
perception that Mr. Olalde-Nieves sought to put distance between himself and law
enforcement by turning into the school parking lot (in summer months, when school was
not in session). All these facts compound the information the law enforcement already
knew from Agent Gerten that Mr. Olalde-Nieves was involved in a drug conspiracy,
closely mapping Eighth Circuit precedent on the issue. See Callison, F. 4th at 1132.
III. THE DRUG DOG SNIFF INDEPENDENTLY PROVIDED PROBABLE
CAUSE TO SEARCH THE VEHICLE.
Lastly, the Court turns to Mr. Olalde-Nieves’s challenge to the dog sniff. Mr. Olalde-
Nieves challenges the validity of the dog sniff. The government counters that Frizko’s
initial alert, before he put his head through the car’s open window, provides an independent
basis of probable cause to justify the law enforcement’s warrantless vehicle search.
The use of a drug dog on the exterior of a vehicle during a traffic stop does not
violate the Fourth Amendment. United States v. Pulido-Ayala, 892 F.3d 315, 318 (8th Cir.
2018). Furthermore, an alert from a certified reliable drug dog provides probable cause to
search a vehicle. United States v. Collier, 116 F.4th 756, 761 (8th Cir. 2024). When
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evaluating the validity of a drug dog sniff, the Court considers “whether all the facts
surrounding a dog’s alert, viewed through the lens of common sense, would make a
reasonably prudent person think that a search would reveal contraband or evidence of a
crime. A sniff is up to snuff whit it meets that test.” Florida v. Harris, 568 U.S. 237, 248
(2013). And under Eighth Circuit precedent, a dog need not ‘indicate’ to the presence of
drugs—an ‘alert’ alone may be sufficient to establish probable cause. United States v.
Holleman, 743 F.3d 1152, 1156 (8th Cir. 2014) (affirming a finding of probable cause
where handling officer testified that dog gave two definitive alerts without a full
indication). This is true so long as the dog handler can “articulate specific, reasonable
examples of the dog’s behavior that signaled to the presence of illegal [drugs].” Id.
The Court finds that Frizko’s initial alert, before he put his head through the open
car window, provided probable cause to search without a warrant. Here, Trooper Beuning
(Frizko’s handler) testified to his understanding that Frizko alerted to the presence of drugs
upon reaching the Chevy Malibu based on the dog’s body language. While a review of the
video footage is not crystal clear as to Frizko’s first alert, Trooper Beuning described
specific details of Frizko’s behavior that constituted an alert at the evidentiary hearing in a
manner sufficient to demonstrate probable cause.
The Court, having determined that several valid bases for probable cause exist,
declines to consider the government’s inevitable discovery argument. The Court therefore
recommends that Mr. Olalde-Nieves’s Motion to Suppress Evidence (Doc. 27) be denied
in its entirety.
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RECOMMENDATION
Accordingly, based on all the files, records, and proceedings above, IT IS
RECOMMENDED that:
1. Defendant Raymundo Olalde-Nieve’s Motion to Suppress Evidence (Doc.
27) be DENIED.
Date: December 1, 2025 s/Douglas L. Micko
DOUGLAS L. MICKO
United States Magistrate Judge
NOTICE
Filing Objections: This Report and Recommendation is not an order or judgment of the
District Court and is therefore not appealable directly to the Eighth Circuit Court of
Appeals. Under Local Rule 72.2(b)(1), “a party may file and serve specific written
objections to a magistrate judge’s proposed findings and recommendations within 14 days
after being served with a copy” of the Report and Recommendation.
A party may respond to those objections within 14 days after being served a copy of the
objections. See Local Rule 72.2(b)(2). All objections and responses must comply with the
word or line limits set forth in Local Rule 72.2(c).
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