USA v. Walker, No. 21-20385 (5th Cir. 2022)
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Defendant pled guilty to one count of being a felon in possession of a firearm. His plea reserved the right to appeal the district court’s denial of his motion to suppress. He challenges the district court’s determination that a firearm and cell phone discovered in his car, as well as statements he made to officers, were admissible.
The Fifth Circuit affirmed. The court explained that here, the officers relied on their computer records that listed Defendant’s warrants. They did not have the complaints underlying the warrants or other information that might have revealed possible invalidity. Without “deliberate, reckless, or grossly negligent” conduct on the part of the police, excluding evidence has little, if any, deterrent value and is therefore unjustified. In sum, the court wrote, there is nothing in the record that would show that the officers’ reliance on the computer records was not objectively reasonable. The district court did not err in applying the good faith exception, and the officers were justified in their reliance on the traffic warrants as a basis for arrest.
Further, the only significant statement was Defendant’s answer to being asked if “there is anything [the officer] should know about” in the vehicle. Defendant responded that there is “something you might take me to jail for if I tell you,” and he then told the officer about a pistol in the console. The statement is not independently significant. Accordingly, the court rejected any prejudicial error from the admission of the statement.
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