United States v. Scott, No. 18-4440 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's motion to suppress the firearm after he conditionally pleaded guilty to possession of a firearm as a convicted felon. The court rejected defendant's reliance on the agreement condition and held that the statutory search condition specifically provides that warrantless searches of supervisees may be undertaken by any post-release supervision officer.
The court also held that, at bottom, the record supported the district court's determination that the warrantless search of defendant's apartment was not for the purpose of furthering general law enforcement goals. Rather, the officers conducted the search to ensure defendant's continued compliance with the terms of his supervision agreement. Finally, because the search of defendant's apartment complied with the statutory condition, no Fourth Amendment violation occurred.