United States v. Daniel Derek Brown (9th Cir. June 2019)

The Court held that there was no reasonable suspicion to detain a defendant who fled upon being approached by police as there is no rule that says flight creates reasonable suspicion per se, the officers never ordered the defendant to stop before activating their lights, and there was no threat of harm or indication that the defendant was acting in any dangerous manner or that the area was dangerous.

United States v. Sergio Diaz-Ortiz (8th Cir. June 2019)

The Court held that a knock-and-talk violation does not mandate suppression when a valid search warrant exists and the knock-and-announce violation has “nothing to do with the seizure of the evidence.” Here, the warrant was valid, and officers would have executed it and seized the evidence regardless of the alleged violation.

United States v. Meamen Nyah (8th Cir. 2019)

Regardless of any alleged failure to execute a search warrant within the time limit in violation of Rule 41, absent any other “constitutional infirmity,” suppression is unwarranted unless the defendant is prejudiced or if officers recklessly disregard the proper procedure. The defendant was not prejudiced here since probable cause continued to exist after the time limit.

United States v. Charles White (8th Cir. June 2019)

In a marijuana farm case, the Court held that law enforcement did not exceed the scope of a permissible knock-and-talk when they returned to the defendant’s house with other narcotics officers after smelling marijuana at the property earlier in the day, as an officer's subjective intent is irrelevant. The Court also affirmed the district court's denial of the defendant's motion to dismiss the marijuana charges based on the Obama-era "Cole memo" directing prosecutors not to prosecute marijuana cases in states where marijuana is legal.

Mitchell v. Wisconsin (U.S. Supreme Court, June 2019)

The Court affirmed the defendant's conviction for a DUI after police took his blood while he was passed out, with a plurality of the  Court holding that conducting a blood test on a defendant while he is passed out is permissible under the “exigent circumstance” exception to the Fourth Amendment’s warrant requirement.
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