United States v. Sylvester, No. 19-2127 (1st Cir. 2021)
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The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute various controlled substance and one count of possession of a firearm in furtherance of a drug-trafficking crime, holding that the district court did not err in denying Defendant's motion to suppress.
Defendant sought to suppress drug evidence and a firearm seized pursuant to a search warrant for the car he was driving when he was arrested on an outstanding federal warrant. In his motion, Defendant argued that the search warrant for the car was invalid because it was issued based on an unlawful inventory search. The First Circuit affirmed the denial of Defendant's motion to suppress, holding that the district court did not err in concluding that (1) the officers had an objectively reasonable non-investigatory purpose; and (2) the inventory search of the car was unlawful.
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