United States v. Crisolis-Gonzalez, No. 12-3807 (8th Cir. 2014)
Annotate this CaseDefendant was convicted of possession with intent to distribute and conspiracy to distribute 50 grams or more of methamphetamine and illegal reentry of an alien. On appeal, defendant challenged the district court's denial of his motion to suppress evidence elicited while agents conducted a "knock and talk" at defendant's residence. The court concluded that there was no evidence of misrepresentation in the agent's request to enter the apartment and the boyfriend and roommate of one of the lessees had actual authority to consent; the agents conducted a lawful protective sweep of the apartment where facts were sufficient to alert the agents as to the possibility that the apartment harbored dangerous individuals; defendant's statement about the location of the gun was a volunteered, spontaneous admission; the circumstances surrounding defendant's consent to search his bedroom was void of even the slightest evidence of coercion; and defendant's post-Miranda statements were lawfully obtained. Accordingly, the court affirmed the district court's denial of the motion to suppress.
Court Description: Criminal Case - suppression. District court's denial of motion to suppress is affirmed. Agent did not mislead occupant during "Knock and Talk" entry and third-party had actual authority to consent to allow entry. Protective sweep was justified by facts alerting the agents to the possibility that the apartment harbored dangerous individuals. Defendant's statement as to the location of a gun was independent from agent's inquiry regarding his immigration status and was a voluntary, spontaneous admission. Defendant's grant of consent to search bedroom was not coerced. Post-Miranda statements were lawfully obtained.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.