United States v. Meyer, No. 20-2958 (8th Cir. 2021)Annotate this Case
The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence and defendant's sentence imposed after he pleaded guilty to one count of sexual exploitation of children. In this case, federal agents, who were concerned that defendant would destroy evidence if he were allowed to go back inside, entered defendant's house without a warrant and took two computers, a cell phone, and a hard drive.
The court concluded that the circumstances were suspicious enough that the agents could have reasonably concluded that there was a substantial chance that defendant was involved in criminal activity. The court also concluded that the officers had a sufficient basis to reasonably believe that defendant would imminently destroy evidence, and thus defendant's conduct created an exigency. Therefore, the warrantless search did not violate the Fourth Amendment because the officers had probable cause, the exigency was real, and it was not of the agents' making. Finally, any error in the district court's statement at sentencing was harmless.
Court Description: [Stras, Author, with Gruender and Benton, Circuit Judges] Criminal Case - suppression. Federal agents entered defendant's house without a warrant and took two computers, a cell phone, and a hard drive, concerned that defendant would destroy evidence if they waited to get a warrant. Meyer's motion to suppress evidence seized was denied and he appeals. Because there was sufficient evidence to suspect that incriminating evidence would be destroyed, exigent circumstances existed, there was probable cause to enter and search the home, and the officers did not create the exigency, there was no Fourth Amendment violation. Any error in district court's statement at sentencing was harmless.