In October 2022, an employee at a Bartlesville, Oklahoma storage facility reported a suspicious unit. Before obtaining a search warrant for the unit, one officer “peeked” into the partially open unit and saw what he believed was methamphetamine, a firearm, and money. Another officer entered and opened a drawer inside the unit. Relying on those observations, police obtained search warrants for the storage unit and for Blasdel’s home, where they found additional drugs and firearms. The district court denied Blasdel’s motion to suppress, and he entered a conditional guilty plea to drug-conspiracy, possession with intent to distribute methamphetamine, and felon-in-possession charges. He was sentenced to 188 months in prison. He appealed the suppression ruling.
The Tenth Circuit held the officers’ pre-warrant incursions into the storage unit were unreasonable warrantless searches in violation of the Fourth Amendment and that evidence obtained as a result must be suppressed. Without inclusion of the invalid searches in the affidavit, police lacked probable cause for the warrant. Nor did the good-faith exception apply, as the affidavit was so facially deficient that any reliance on the warrant was unreasonable.
Because the search warrant for the defendant’s house also relied on evidence derived from the unlawful storage-unit search, that evidence was fruit of the poisonous tree and had to be suppressed as well. The panel therefore reversed the denial of suppression, vacated the conviction and 188-month sentence, and remanded.
Appeal from the Northern District of Oklahoma.
Opinion by Seymour, joined by Phillips and Bacharach.