United States v. Smith, No. 21-1104 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized through execution of a search warrant of his motel room, his statements to police during an interrogation, and an eyewitness identification. The court concluded that the information in the affidavit was stale where one of the charges against defendant was for a continuing offense, and there was a substantial basis for finding probable cause to search the motel room for firearms. The court also concluded that the district court did not not err in denying defendant's request for a Franks hearing where, even if the affidavit were supplemented by facts defendant contends were improperly omitted, a judge could reasonably conclude that probable cause existed for finding firearms in Room 220. The court further concluded that, it need not decide whether officers had consent to enter, because even if consent was lacking, the challenged evidence was admissible under the inevitable discovery doctrine. Finally, the court concluded that defendant knowingly and intelligently waived his Miranda rights, and rejected defendant's challenge to the witness's identification from a mug shot.
Court Description: [Wollman, Author, with Smith, Chief Judge, and Benton, Circuit Judge] Criminal case - Criminal law. Information supplied in the affidavit in support of the search warrant application was not stale and provided a substantial basis for finding probable cause to search defendant's motel room for firearms; the district court did not not err in denying defendant's request for a Franks hearing because even if the warrant application was supplemented by the facts defendant contends were improperly omitted from the affidavit, a judge could reasonably conclude probable cause existed; even if the officers' entry into the room was not consensual, the challenged evidence was admissible under the inevitable discovery rule; defendant knowingly and intelligently waived his Miranda rights; challenged to witness's identification of defendant from a mug shot rejected as there was not a very substantial likelihood of irreparable misidentification given the witness was staying in an adjacent room and had spoken with defendant about a gun shot that came into her room from his. [ December 21, 2021 ]
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