United States v. Pile, No. 15-1882 (8th Cir. 2016)
Annotate this CaseDefendant appealed the district court's denial of his motion to suppress evidence found in his camper pursuant to a search warrant and any statements following the search. The court concluded that the district court did not err in applying the protective sweep exception to the lieutenant's conduct and denying defendant's motion to suppress. In this case, the lieutenant did not violate defendant's Fourth Amendment rights when he opened the door to the camper, asked the individual inside to come out, and, in the process, observed contraband. The lieutenant had reasonable suspicion to conduct the sweep based upon defendant's declaration that his friend was inside the camper. Accordingly, the court affirmed the judgment.
Court Description: Per Curiam - Before Murphy, Smith and Benton, Circuit Judges] Criminal case - Criminal law. The police officer who conducted a protective sweep of defendant's camper reasonably believed there was another person present and the district court did not err in ruling evidence subsequently seized pursuant to a warrant based on the officer's observations during the sweep was admissible.
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