United States v. Jorgensen, No. 16-1109 (8th Cir. 2017)
Annotate this CaseThe government challenges the district court's grant of defendant's motion to suppress physical evidence obtained as a result of a warrant search of defendant's home. The court concluded that the district court committed plain error in not considering whether there was a sufficient factual nexus between the constitutional violation - the recklessly untrue warrant affidavit - and defendant's statements to an agent two days later. In this case, the factors supporting this conclusion include the fact that defendant received Miranda warnings, the temporal proximity between defendant's arrest and his interview with the agent, several intervening circumstances weighing against suppression, and the unintentional error in describing for an issuing magistrate what the deputy believed to be probable cause was not purposeful or flagrant misconduct. Accordingly, the court reversed and remanded for further proceedings.
Court Description: Loken, Author, with Gruender and Benton, Circuit Judges] Criminal case - Criminal law. The district court erred in suppressing defendant's post-arrest statements as there was not a sufficient nexus between the constitutional violation requiring suppression of a search (a recklessly untrue warrant affidavit) and defendant's statements two days later; among the factors supporting that conclusion are the facts that defendant received Miranda warnings, two days had passed, the agent who took the statements was from a separate law enforcement agency not connected to the violation and the initial violation was unintentional. [ January 11, 2017
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