United States v. Arredondo, No. 20-1382 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's grant of defendant's motion to suppress evidence of medicine vials, concluding that the plain view exception does not apply where the incriminating character of the vials was not immediately apparent. Furthermore, there is nothing in the record suggesting that the officer had specialized expertise or training with regard to narcotics such that his specific knowledge could be a basis for finding probable cause.
In this case, officers arrived at the residence after a neighbor's report of a woman screaming and crying, they entered the home without consent to check on the woman, found her extremely intoxicated but unharmed, and discovered the small glass vials. The court explained that, when one of the officers picked up the vials, held them higher to get a better view, and turned them to read the labels, he had no idea of the contents. At that moment, the vials had been searched and seized, before he had probable cause to believe they were an illegally possessed controlled substance.
Court Description: [Erickson, Author, with Gruender and Kobes, Circuit Judges] Criminal case - Criminal law.The plain view exceptions did not apply to an officer's warrantless seizure of pill vials as the incriminating character of the vials was not immediately apparent; the district court did not err in granting defendant's motion to suppress the vials. Judge Gruender, dissenting
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