United States v. Harris, No. 12-3247 (8th Cir. 2014)
Annotate this CaseDefendant conditionally pleaded guilty to being a felon in possession of a firearm. On appeal, defendant challenged the district court's denial of his motions to suppress. The government argued that the police had a reasonable suspicion that defendant was violating several of Missouri's gun laws and contended that, in any event, the police acted reasonably under the community caretaker doctrine. In this instance, officers responded to a call about a gun falling out of the pocket of a man sleeping outside of a bus station. Unlike most typical Fourth Amendment encounters, the governmental interest in vindicating the officers' actions here was not encompassed in the enforcement of criminal statutes but, instead, in the officers' obligation to help those in danger and to protect property. Under the circumstances, the officers' decision to handcuff defendant until they could safely awaken him and obtain more information was reasonable. Finally, the scope and duration of the intrusion were also reasonable. Accordingly, the court affirmed the district court's denial of defendant's motion to suppress.
Court Description: Criminal case - Criminal law. Officers called to a bus station upon a report that a man sleeping in the station had a gun falling out of his pants were acting within their community caretaker capacity, and their action in seizing the weapon from defendant while he was asleep was justified by the risks the exposed and unguarded weapon posed; officers' decision to handcuff defendant until they could safely awaken him and obtain information was reasonable.
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