United States v. Melchizedek Hayes, No. 22-3247 (8th Cir. 2023)
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Defendant pleaded guilty to unlawful possession of a firearm as a prohibited person. He argued that the district court erred when it denied his motion to suppress evidence seized during a search of his home.
The Eighth Circuit affirmed, concluding that there was no error in admitting the evidence. The court explained that officers may seize an effect without a warrant under the “plain view doctrine” if they are lawfully present in a place to view the object, the incriminating character of the object is immediately apparent, and the officers have a lawful right of access to the object. Here, once the officers were lawfully present in Defendant’s house based on his stepfather’s apparent authority to consent, the officers permissibly seized the Molotov cocktails as objects in plain view in the bathroom and kitchen.
Defendant suggests that even if the police officers were lawfully present in his home and the incriminating character of the explosive devices was immediately apparent, the officers were required to obtain a warrant before making a seizure. But “where the elements of the plain view doctrine are met, the fact that the officers could have left and obtained a warrant does not invalidate the justification for seizing the property.” Accordingly, the district court did not err when it concluded that the officers lawfully seized the items from Defendant’s bathroom and kitchen.
Court Description: [Colloton, Author, with Wollman and Gruender, Circuit Judges] Criminal case - Criminal law. The search of defendant's house was permissible without a warrant because the police officers reasonably relied on the apparent authority of defendant's stepfather to consent to the search; once inside the residence, the officers were entitled to seize items (Molotov cocktails and other explosive materials) whose incriminating character was immediately apparent.
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