United States v. Coleman, No. 17-2644 (8th Cir. 2018)
Annotate this CasePhillips, who resided with Coleman, called 911, stating that Coleman had punched her and had a gun. North Little Rock Officer Crowder responded, finding Phillips outside the residence with facial injuries. Phillips opened the door. She and Crowder entered the residence, where Crowder confronted and arrested Coleman after a struggle that involved the use of a taser. Crowder found a large bag of white substance and a large amount of cash in Coleman's pockets, small baggies of white powder on the stairwell, and a handgun and another bag of cocaine in a loveseat near where Coleman was arrested. Additional officers responded and discovered firearms and drugs during a protective sweep of the residence and a warrant search the following day. At a hearing, Phillips contradicted Officer Crowder, denying stating that Coleman struck her and was armed, and denying opening the door and escorting Crowder inside. The Eighth Circuit affirmed the denial of a motion to suppress; Coleman’s convictions for possession with intent to distribute controlled substances and conspiracy to possess with intent to distribute, 21 U.S.C. 841(a)(1), (b)(1)(A), 846, being a felon in possession of a firearm, 18 U.S.C. 922(g)(1), and possession of a firearm in furtherance of drug trafficking, 18 U.S.C. 924(c)(1)(A), and his 161-month sentence. Phillips’s testimony established that she possessed common authority over the premises. The court explicitly credited Crowder’s testimony as more accurate.
Court Description: Loken, Author, with Benton and Shepherd, Circuit Judges] Criminal case - Criminal law. Defendant's girlfriend had common authority over their residence and could invite the officers into the residence to investigate her domestic violence complaint; defendant's subsequent objection to the officers' presence did not invalidate their lawful entry; protective sweep of the premises after defendant's arrest was a valid search; the warrant officers obtained to conduct a full search was sufficiently particular; drug sniff and search of car parked in the driveway were permitted under the warrant's language permitting search of the premises and curtilage; evidence was sufficient to support defendant's convictions for possession of drugs with intent to distribute, for conspiracy to possess drugs with intent to distribute and for being a felon in possession of a firearm.
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