United States v. Short, No. 20-1533 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence found in a warrantless search of his vehicle and subsequent search of his apartment. In this case, defendant conditionally pleaded guilty to possessing a firearm in furtherance of a drug trafficking crime in violation of 18 U.S.C. 924(c)(1)(A)(i).
The court concluded that the officers indisputably had probable cause to search defendant's vehicle, and an easily repairable flat tire did not cause the vehicle to lose its inherent mobility. Therefore, the automobile exception applied and the district court properly denied the motion to suppress evidence resulting from the vehicle search. The court also concluded that the district court did not abuse its discretion in denying a Franks hearing where the court agreed with the district court that defendant's assertions failed to show that an investigator deliberately or recklessly omitted various details from his affidavit. Even if defendant had made a sufficient showing of deliberate or reckless omissions, the affidavit contained other information that was sufficient to support a finding of probable cause. Finally, the court concluded that defendant's sentence was not substantively unreasonable where the district court imposed an upward variance in light of the serious nature of the underlying events. In this case, the district court did not abuse its substantial sentencing discretion in weighing the 18 U.S.C. 3553(a) factors.
Court Description: [Loken, Author, with Grasz and Kobes, Circuit Judges] Criminal case - Criminal law and Sentencing. Even though defendant's vehicle was temporarily immobilized by a flat tire, the officers indisputably had probable cause to search the car, and an easily repaired flat tire did not cause the vehicle to lose its inherent mobility; as a result, the automobile exception applied, and the district court properly denied defendant's motion to suppress evidence seized from the vehicle; the district court did not err in refusing to hold a Franks hearing based on defendant's allegations that the detective who completed the search warrant application omitted key information; the district court did not err in determining that defendant failed to establish the detective deliberately or recklessly omitted information from the application; the district court did not impose a substantively unreasonable sentence when it imposed an upward variance based on the serious nature of the underlying events.
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