United States v. Thompson, No. 19-3381 (8th Cir. 2020)Annotate this Case
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.