United States v. Thompson, No. 19-3381 (8th Cir. 2020)
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The Eighth Circuit affirmed the district court's denial of defendant's motions to suppress in a case where defendant entered a conditional plea of guilty to one count of possession with intent to distribute heroin and one count of possession of a firearm in furtherance of a drug trafficking crime.
The court held that the GPS vehicle warrants were supported by probable cause and, even if the warrants lacked probable cause, the Leon good-faith exception applies to the warrants where the officers had an objectively reasonable belief in light of the totality of the circumstances; law enforcement needed a warrant based on probable cause to access cell phone location records; even if the cell phone orders lacked probable cause, the good faith exception applies; the evidence gathered over the course of the investigation was sufficient to establish probable cause; and, once the officers found heroin in defendant's car, they had probable cause to arrest him. The court also held that defendant's pre-Miranda statements were admissible because he was not in custody at the time; defendant's statements made while he was in custody were admissible under the public-safety exception; and other statements at issue were voluntary. Finally, the court denied defendant's motion for leave to file a pro se supplemental brief.
Court Description: [Kelly, Author, with Erickson and Stras, Circuit Judge] Criminal case - Criminal law. The state court GPS vehicle warrants were supported by probable cause; even if the warrants lacked probable cause, the Leon good-faith exception would apply as the officer had an objectively reasonable belief that probable cause existed for the vehicle warrants; probable cause was required for the cell phone orders but even if the orders lacked probable cause, the good-faith exception applies; the officer had probable cause to stop and search defendant's car him based on the information gained through the investigation; once the officer found heroin in the car, he had probable cause to arrest defendant; the district court did not err in determining defendant's pre-Miranda statements were admissible; his first statements were admissible because a person would not reasonably believe he was in custody when they were made; the second set of statements were admissible under the public-safety exception; the third set of statements were voluntary and not in response to interrogation and were admissible.
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