United States v. Flores, No. 17-1510 (1st Cir. 2018)Annotate this Case
The First Circuit affirmed the judgment of the district court determining that probable cause existed for the arrest of Appellant and refusing to suppress evidence seized during a warrant-back search of Appellant’s hotel room, despite the officers’ earlier unlawful entry into that room.
The Court held (1) the district court did not err in determining that Appellant’s de facto arrest comported with the strictures of the Fourth Amendment; and (2) the district court did not err in applying the independent source doctrine to validate the warrant-backed search of Appellant’s hotel room, thus permitting the government to use the evidence obtained as a result of that search, notwithstanding the earlier warrantless entry into that room.