United States v. Shaun Farrington, No. 21-2974 (8th Cir. 2022)
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A jury convicted Defendant of possession with intent to distribute methamphetamine and conspiracy to distribute methamphetamine in violation of 21 U.S.C. Sections 841(a)(1) and 846. He appealed the district court’s denials of his motion to suppress evidence, his motion to strike a juror for cause, and his motion to admit a portion of a video recording.
The Eighth Circuit affirmed Defendant’s convictions. Defendant argued that the seizure and detention of the lockboxes was unreasonable under United States v. Place, 462 U.S. 696 (1983). But “Place had nothing to do with the automobile exception and is inapposite.” See Acevedo, 500 U.S. at 578 (noting that the Supreme Court has consistently “explained that automobile searches differ from other searches” and has denied the applicability of cases that “do not concern automobiles or the automobile exception” to cases involving the automobile exception). Therefore, the district court did not err in denying Defendant’s motion to suppress. Further, the court wrote there was no abuse of discretion because the juror stated that she could remain fair and would listen to the detective’s testimony before deciding if she believed it.
Finally, Defendant claimed that the “partial recording and the Government’s characterization of it . . . gave a misleading and unfair understanding of the meaning of Defendant’s statement to the jury.” But he offers no explanation of how the recording was misleading.
Court Description: [Gruender, Author, with Colloton and Melloy, Circuit Judges] Criminal case - Criminal law. A delay of a few hours between a drug dog sniff and the securing of a warrant and the opening of defendant's lockboxes did not violate defendant's Fourth Amendment rights, and the court did not err in denying defendant's motion to suppress; the court did not err in denying defendant's motion to strike a juror who had previously corresponded with a government witness, a police officer to whom she had reported a possible crime, as the juror stated she could remain fair and would listen to the officer's testimony before deciding if she believe it; the juror's explicit statement of impartiality defeats defendant's attempt to show actual partiality; the district court did not abuse its discretion in denying defendant's motion to admit additional portions of a jailhouse recording as defendant failed to show how the additional portion was necessary to explain or contextualize the admitted portion, correct a misleading impression, or ensure a fair and impartial understanding.
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