United States v. Smith, No. 15-1742 (8th Cir. 2016)
Annotate this CaseDefendant pled guilty to possession of a firearm by a prohibited person and then challenged the warrantless search of his residence. The court concluded that the officers acted in their community caretaking function when they entered the residence where the officers received a call from a concerned member of the community regarding the safety of another community member (defendant's ex-girlfriend). On the scene, the officers learned further details indicating serious concern for the safety of defendant's ex-girlfriend and establishing multiple reasons why she would be at defendant’s residence and held against her will or in danger. The court also concluded that the officers reasonably believed an emergency situation existed that required their immediate attention in the form of entering defendant’s residence to search for the ex-girlfriend. Furthermore, the scope of the encounter was carefully tailored to satisfy the purpose. The firearm at issue was lying on the bed in the bedroom where the ex-girlfriend was located and it was partially covered by a bed sheet. Therefore, the firearm is admissible under the plain view doctrine. Accordingly, the court affirmed the district court's denial of defendant's motion to suppress.
Court Description: Shepherd, Author, with Chief Judge Riley and Smith, Circuit Judges] Criminal Case - suppression. The specific, articulable facts showed that officers had a reasonable belief that Wallace was in danger and that they acted in their community caretaking function when they entered Smith's residence without a warrant. The scope of the encounter was carefully tailored to satisfy their purpose of locating Wallace. The firearm at issue, lying on the bed in the bedroom where Wallace was located, was in plain view and was admissible under the plain view doctrine.
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