United States v. Sanders, No. 19-1497 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a firearm. The court held that the officers acted in their community caretaking function when they entered the home of defendant's girlfriend without a warrant in response to a domestic disturbance phone call from the girlfriend's daughter. Once the officers arrived at the scene, they learned further details that indicated a serious concern for the safety of the girlfriend and the children who were inside the house.
The court also held that the scope of the encounter was carefully tailored to satisfy the officers' purpose for entry. Furthermore, a warrant was not needed to search areas that may conceal the gun, because the daughter told officers that defendant had a gun. Therefore, the officer had an objectively reasonable belief that a gun was inside the house. Finally, the court held that the district court did not err by applying a two-level enhancement for obstruction of justice under USSG 3C1.1, and the district court did not err in refusing to reduce defendant's applicable Guidelines range to account for acceptance of responsibility.
Court Description: [Erickson, Author, with Grasz and Kobes, Circuit Judges] Criminal case - Criminal law and sentencing. Based on the domestic disturbance call made to the police and the officers' observations at the scene, the officers reasonably believed that their warrantless entry into the home was a justifiable exercise of their community caretaking function; the scope of the encounter was carefully tailored to satisfy the purposes for the entry; a warrant was not needed to search areas that might conceal a threat if the officers have an objectively reasonable basis to believe that an immediate act was required to preserve safety; here, exigent circumstances justified the officers' efforts to locate and secure a handgun; no error in imposing a two-level obstruction-of-justice enhancement under Guidelines Sec. 3C1.1 where defendant attempted to influence a witness; nor did the court err in denying defendant acceptance of responsibility based on this conduct.
The court issued a subsequent related opinion or order on July 16, 2021.
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