United States v. Baker, No. 19-5636 (6th Cir. 2020)
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Officer Render saw a new warrant to arrest Baker for receiving stolen property. A judge had issued this warrant on the ground that Baker had received a stolen Nextbook tablet. The subject who pawned the tablet revealed that the tablet was purchased in Madisonville from Baker. Render and Officer Knelson met at the listed address, which appeared to be a hybrid residence and pawnshop, with a sign flashing “open.” Through the windows, Render could see merchandise and a man. The door was locked. The man voluntarily let him in and acknowledged that he was Baker, In response to a request for identification, Baker walked through a door. According to Render, officers should maintain visual contact with arrestees to ensure they are not getting firearms, so he followed Baker. The door led to a kitchen and then another door led to another area, where Baker retrieved his wallet. Render noticed jars of marijuana and a rifle in plain view and asked Baker if he was a convicted felon. Baker confirmed he was. Render left to secure a search warrant. Knelson searched Baker incident to his arrest and found crack cocaine. With a search warrant, officers found more crack cocaine, marijuana, firearms, and methamphetamine.
The Sixth Circuit affirmed the denial of Baker's motion to suppress the evidence. The officer acted reasonably in monitoring Baker’s movements. The affidavit supporting the warrant contained enough of a connection between Baker and a crime that the officers could reasonably rely on the judge’s probable-cause finding.
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