United States v. Crutchfield, No. 19-3767 (8th Cir. 2020)Annotate this Case
The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that the district court did not err by denying defendant's motion to suppress where police entry into the residence in response to the call for medical aid for a shooting victim was not constitutionally objectionable.
In this case, given the fact of a shooting and the other information known to officers at the time, exigent circumstances made it permissible to look into other rooms to ensure the absence of a shooter or additional victims. Furthermore, the officers almost immediately saw ammunition and suspected narcotics in plain view; officers were permitted to secure the exterior of the residence for the same reasons; and, to the extent defendant takes issue with the officers looking on the adjacent property, any objects found there were abandoned. The court concluded that defendant's arguments do not merit relief where the officers were not "lingering" or "frolicking" in a manner inconsistent with a security sweep. Moreover, no information gleaned through lingering in the home, or re-entering after the ambulance departed, aided in securing the search warrant. Finally, the court held that the district court did not clearly err by finding that defendant possessed the firearms in connection with another felony under USSG 2K2.1(b)(6)(b).