Fourth Amendment

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.

The Court affirmed the district court’s denial of the defendant’s motion to suppress based on a federal search warrant that was based on a defective state warrant. Though the Court agreed with the defendant that “any probable cause deficiency with the state search warrant would, as a matter of law and logic on these facts, heavily inform any conclusion we reach about the sufficiency of probable cause in the federal warrant application,” the Court upheld denial of the motion to suppress since the federal agents acted in good faith when they relied on the state warrant. The Court held that the focus should have been on the federal agents, who had no reason to question the integrity of the state proceedings, though the Court acknowledged that the result may have been different if the record reflected that the FBI had more knowledge about the state court proceedings

The Court held that a warrant obtained after an illegal entry was an independent legal source for the drug evidence where the warrant application was supported by probable cause without the tainted information, and the Government’s decision to seek the warrant was not motivated by the illegal entry, despite inconsistent testimony from the agent at the suppression hearing and the agents’ decision to confirm the presence of methamphetamine before seeking a warrant. 

The Court held that suppression was not warranted where the defendant waived his Miranda rights, despite officers allowing him to take valium to avoid withdrawals, where there was other evidence indicating he was lucid, and where the defendant voluntarily consented to the search of his apartment upon signing a Written Consent.

The Court held that there was no reasonable suspicion to detain a defendant who fled upon being approached by police as there is no per se rule that says flight creates reasonable suspicion, 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.

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.

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.