Christopher Nation v. Commonwealth of Kentucky
2023-CA-0866
Ky. Ct. App.Mar 21, 2025Background
- Christopher Nation, a convicted felon, was found in a shed behind his mother's home by Nelson County Sheriff's officers executing an arrest warrant.
- Officers received an anonymous tip and corroborated that Nation often stayed in the shed.
- Two firearms (a shotgun and a .22 rifle) were found inside the shed with Nation.
- Nation moved to suppress evidence of the firearms, arguing the search and seizure were unlawful.
- The trial court denied Nation’s motion to suppress, crediting police testimony and applying the plain view and officer safety exceptions to the warrant requirement.
- Nation entered a conditional guilty plea and appealed the suppression decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of entry onto property to execute arrest warrant | Officers needed probable cause to enter property or shed | Officers needed only reason to believe Nation was present (not PC) | Officers had sufficient reason to believe Nation was there |
| Warrantless search/seizure of firearms | Firearms seized unlawfully; police improperly entered shed without consent or warrant | Entry justified for officer safety and plain view; no consent required | Seizure lawful under plain view and protective sweep exceptions |
| Weight of conflicting testimony | Testimony from Nation's mother discredited officer's account of entry | Officer's version more credible; officers could see inside without prying | Court found officer's testimony more credible |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (1980) (arrest warrant allows limited entry into suspect's dwelling if reason to believe suspect is inside)
- Coolidge v. New Hampshire, 403 U.S. 443 (1971) (plain view exception to warrant requirement)
- Maryland v. Buie, 494 U.S. 325 (1990) (protective sweep exception for officer safety)