United States v. Thompson, No. 15-2008 (7th Cir. 2016)
Annotate this CaseAn informant bought crack from Thompson at the La Crosse apartment where Thompson was staying. The informant was equipped with two hidden audio-video recording devices that captured the transaction. Thompson moved to suppress the video recordings The district court denied the motion because Thompson had invited the informant into the apartment, forfeiting his expectation of privacy as to anything he voluntarily disclosed. The court imposed a sentence of 36 months’ imprisonment, significantly below the guidelines range of 151 to 188 months, based on Thompson’s status as a career offender because of two convictions for a controlled substance offense. The Seventh Circuit affirmed his conviction for possessing for distribution the crack found during execution of the search warrant. 21 U.S.C. 841(a)(1) and his sentence. The court rejected arguments that the informant exceeded the scope of his license to be in the apartment as an invitee when he recorded videos of the encounter and that making the video recordings violated his reasonable expectation of privacy because the information they revealed was not voluntarily disclosed.
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