USA v. Jefferson, No. 22-30690 (5th Cir. 2023)
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The United States Court of Appeals for the Fifth Circuit affirmed the district court's denial of Palma L. Jefferson Jr.'s suppression motions and his sentence related to his conviction for various drug trafficking charges, and for being a felon in possession of a firearm. The case arose after an anonymous tip led to a police investigation of Jefferson. The police did not find the described vehicle transporting drugs, but the tipster provided additional information leading to Jefferson's residence. The tipster provided live directions via video chat, allowing the police to locate Jefferson's apartment. When police approached Jefferson, they claimed he admitted to having cocaine and a firearm in his apartment, which led to his arrest.
Jefferson challenged the legality of his arrest, the search of his apartment, and the use of his initial confession. He argued that his initial stop by the police amounted to a de facto arrest without probable cause and that the officers unlawfully entered and searched his apartment without a warrant. He further argued that his confession, if made, was unlawfully obtained. Jefferson also challenged the calculation of drug quantities and the application of a dangerous weapon enhancement in his sentence.
However, the court found that Jefferson's initial stop by the police was an investigatory stop based on reasonable suspicion, not a de facto arrest. Even if the officers unlawfully entered and searched his apartment, the evidence obtained could still be admitted under the independent source doctrine, as it could be obtained through other lawful means. The court also upheld the drug quantity calculation and dangerous weapon enhancement in Jefferson's sentence.
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