Fourth Amendment

The Court held that the district court did not err in refusing to consider the defendant’s untimely motion to suppress, since the defendant’s failure was based on a strategic decision. Moreover, the sentencing court did not err in refusing to grant a downward departure for acceptance of responsibility where the defendant challenge his factual guilt throughout the proceedings and at trial.

The Court affirmed the district court’s finding that officers’ warrantless search of a home was justified under the “emergency aid exception.” The Court held that the officers had a reasonable belief that a dog’s whimpering inside the house was a human in need of emergency aid based on their initially responding to a 911 regarding gun shots, the defendant’s belligerent behavior prior to his arrest, and the officers’ belief that someone else may have been in the house.

In an 8-1 opinion, the Supreme Court held that an officer has reasonable suspicion justifying a traffic stop when he runs a vehicle’s license plate and learns that the registered owner’s license has been revoked or suspended. The Court held that it is reasonable for an officer to assume that the vehicle’s driver is the registered owner, even where the registered owner’s license has been suspended, because the data shows that many individuals who have suspended licenses continue to drive anyway.

In a matter of first impression involving the use of ShotSpotter, GPS-enabled technology that detects gunfire, the Court held that there was reasonable suspicion to stop a vehicle emerging from an area where gunfire was detected based on the short lapse of time between the detection and the stop, the vehicle’s proximity to the area, the behavior of the occupants, and other circumstances.

The Court affirmed the defendant’s conviction, holding that the good faith exception applied to law enforcement’s search of two separate addresses despite only identifying one address in the search warrant. The Court noted that the lack of signs distinguishing the two addresses and their proximity made it reasonable for the officers to treat the two addresses as one.

The Court affirmed the defendant’s conviction, holding that a traffic stop was not unlawfully prolonged where the officers had reasonable suspicion to stop the vehicle and asked questions about the driver and passengers’ reasons for travel and destination, and new reasonable suspicion was created based on “implausible elements” and contradictory answers in the driver and passengers’ responses to the questioning.

The Court held that the defendant’s consent for an undercover officer to enter his house was not tainted by “police deception.” While the officer did not identify himself as law enforcement to the defendant when he asked to talk to the defendant’s wife and to step inside “to get out of the cold,” the officer did not take any affirmative acts to conceal his identity from the defendant. The Court also held that Wooden’s burglary convictions under Georgia law qualified as crimes of violence under the ACCA.

The Court affirmed the denial of the defendant’s motion to suppress, holding that fingerprints obtained as a result of an unlawful arrest should not be excluded under the routine booking exception to the Fourth Amendment.

The Court upheld a stop and frisk where, despite evidence that the defendant was not wearing a hoodie and the alleged suspect was reported as wearing a hoodie, the defendant acted nervously around the officer, the officer already knew the defendant was a convicted felon, and there was a “bulge” in the defendant’s pocket.

The Court held that the officer violated the defendant’s Fourth Amendment right by opening his phone after the defendant’s arrest, where the officer saw a picture of a firearm, but affirmed the district court’s denial of the motion to suppress under the independent source doctrine, since the officers had already seen the picture on another occasion, and since there was probable cause notwithstanding the tainted picture.