United States v. Dyer, No. 21-3087 (3d Cir. 2022)
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A York, Pennsylvania woman told law enforcement that Dyer had attacked her with a handgun, trafficked women, and sold drugs from his house. They obtained a warrant to search Dyer’s home for “[f]irearms, illegal drugs, [and] cell phones” after a search of his criminal history revealed that Dyer, a felon, may have possessed a firearm. Officers executed the warrant the following day; they found Dyer, who directed them to a firearm that matched the woman's description. They also seized “the Box” containing pills, drug packing materials, and ID” from a shelf in Dyer’s son’s bedroom. ATF Agents obtained another warrant to search Dyer’s residence, garage, and the surrounding curtilage for drugs and drug paraphernalia; they found pentylone capsules (bath salts), and digital scales with cocaine residue.
Charged with knowingly possessing a firearm as a convicted felon, possession of a firearm in furtherance of a drug trafficking crime, criminal conspiracy to distribute and possess pentylone with the intent to distribute, and possession of pentylone with the intent to distribute. Dyer moved to suppress all the evidence. The court ultimately refused to exclude the firearm properly seized during the first search and the drugs, digital scales, and packaging seized during the second search. Dyer pled guilty to the felon in possession of a firearm charge, Dyer appealed the admission of the Box. The Third Circuit affirmed. The Box was immaterial to his case and admitting it was at most harmless error.
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