United States v. Evans, No. 16-1485 (8th Cir. 2017)
Annotate this CaseThe government appealed the district court's grant of defendant's motion to suppress evidence, a firearm in this case, found on his person incident to arrest for an unrelated crime. The court concluded that the district court did not err in finding that the officers lacked probable cause to arrest defendant for rape where the victim did not provide a positive identification of defendant sufficient to establish probable cause. The court explained that defendant lacked the essentially defining features of the victim's identification of her attacker, and the subsequently developed discrepancies were so significant that they constituted a significant obstacle to a finding of probable cause. Accordingly, the court affirmed the judgment.
Court Description: Wollman, Author, with Riley and Kelly, Circuit Judges] Criminal case - Criminal case. The district court did not err in determining the police lacked probable cause to arrest defendant as the victim did not provide a positive identification sufficient to establish probable cause; defendant lacked essential defining physical features contained in the victim's description of her assailant and, together with subsequently developed information, these discrepancies were so important that they constituted a significant obstacle to finding probable cause; the district court did not err in suppressing the firearm seized during defendant's arrest.
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