United States v. Sierra-Ayala, No. 20-1145 (1st Cir. 2022)Annotate this Case
The First Circuit affirmed Defendant's conviction for four offenses relating to Defendant's possession of a handgun with an obliterated serial number and drugs found within the bag that he was carrying, holding that Defendant was not entitled to relief on his allegations of error.
On appeal, Defendant challenged the denial of his motion to suppress evidence recovered during his arrest, alleging that his seizure violated his Fourth Amendment rights and that he was coerced into handing over the bag to law enforcement. The First Circuit affirmed, holding (1) the officer lacked reasonable suspicion to justify the initial seizure of Defendant but an intervening voluntary act provided independent probable cause to arrest Defendant; (2) suppression was not warranted under the fruit-of-the-poisonous-tree doctrine; and (3) the district court did not abuse its discretion in imposing limitations on cross-examination during the trial.