United States v. Mayo, No. 23-1412 (8th Cir. 2024)
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The case revolved around Darron Mayo, who was appealing the denial of his motion to suppress evidence obtained from a hidden camera placed by police officers across his apartment door. The evidence from this camera was used to obtain a search warrant for Mayo's apartment, where police found drugs, paraphernalia, cash, a loaded pistol, and an iPhone containing incriminating photographs and videos.
Mayo argued that the footage from the hidden camera violated his Fourth Amendment rights and that the search warrant was deficient after removing evidence obtained from the camera. He also contended that the good-faith exception to the exclusionary rule did not apply. The United States Court of Appeals for the Eighth Circuit, however, affirmed the decision of the District Court, ruling that the probable cause affidavit remained sufficient even when the evidence from the hidden camera was omitted.
The court cited four sets of related facts supporting this conclusion. First, various drugs, a scale, and stolen handguns were found in a car associated with Mayo. Second, Mayo's fingerprints were found on a handgun magazine, and a video linked him to the vehicle. Third, during a traffic stop, Mayo gave a false name, marijuana was found in the car, and he made incriminating phone calls recorded by a police dash camera. Fourth, utilities in Mayo's name connected him to the apartment in question. These facts indicated a fair probability that contraband or evidence of a crime would be found in his apartment. Therefore, the court held that the hidden camera footage was not necessary to establish probable cause.
Court Description: [Smith, Author, with Colloton, Chief Judge, and Loken, Circuit Judge] Criminal case - Criminal law. Assuming the footage from a hidden camera in the hallway of defendant's apartment would be suppressed, the other evidence the police submitted in support of the search warrant application was sufficient to support a probable cause finding and the issuance of the warrant for defendant's apartment; there was other evidence of his drug and firearm possession, evidence that defendant was seeking to have another man hide or remove contraband in the apartment, and that he was the resident of the apartment.
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