United States v. Halter, No. 20-1219 (8th Cir. 2021)Annotate this Case
The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress and his sentence for being a felon in possession of a firearm. The court concluded that the seizure of defendant was justified under the community caretaker exception where law enforcement received a report that a little girl's mother heard her daughter screaming and crying during a phone call with the girl's father; the mother also reported that the father had a firearm and threatened to kill anyone else who tried to come get the child; and, because defendant left his house before officers could respond, they were justified in effecting a traffic stop on him in order to conduct a welfare check on the girl. The court explained that the escalation of the encounter occurred only because defendant chose to escalate it by his own threatening conduct in response to the welfare check, and the officers' response was reasonable. The court also concluded that defendant's sentence was reasonable where the district court properly calculated the guidelines range and weighed the relevant 18 U.S.C. 3553(a) factors.