United States v. Mathews, No. 14-2574 (8th Cir. 2015)
Annotate this CaseMatthews’s girlfriend, the mother of his child, reported theft of a firearm. She identified Matthews as a suspect and suggested that Matthews was trafficking heroin. Matthews lived in an apartment in a secure building, to which the owner had granted police access by a key in a lockbox. Their apartment was one of 40-50 opening onto a common hallway. Police went, with a trained dog, to conduct a drug sniff in that hallway outside Matthews’s apartment. The dog alerted to drugs. The next month police returned with the same dog and conducted another drug sniff outside Matthews’s apartment. The dog again alerted, but did not alert when police led it to other apartment doors. A state judge issued a warrant. Executing the warrant, police recovered drug paraphernalia, a digital scale, trace amounts of heroin, and the gun Hines had reported stolen. Matthews’s motion to suppress the evidence was denied. He was convicted as a felon in possession of a firearm, 18 U.S.C. 922(g)(1); 924(a).The Eighth Circuit affirmed the conviction and 96-month sentence. In conducting the 2013 drug dog sniffs, police reasonably relied on precedent that a sniff of the apartment door frame from a common hallway does not constitute a search. The court properly rejected Matthews’s claims regarding his intent to return the gun and applied a stolen-firearm enhancement
Court Description: Wollman, Author, with Colloton, Circuit Judge, and White, District Judge] Criminal case - Criminal case and sentencing. Assuming without deciding that the warrantless drug dog sniff outside the door to defendant's apartment violated defendant's Fourth Amendment rights as construed in Jardines, at the time the officers conducted the search, they reasonably relied on binding circuit precedents sanctioning such sniffs, and the exclusionary rule did not preclude the use of the evidence in a search-warrant application; no error in imposing a two-level enhancement under Guidelines Sec. 2K2.1(b)(4) for possession of a stolen firearm
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