Jose Doe v. Dave Goodman
691 F. App'x 272
| 8th Cir. | 2017Background
- Special Agent Jesse Smith investigated child-pornography uploads tied to an IP address at a Minot residence and obtained a warrant to search that single-family home for electronic evidence.
- Officers executed the warrant, found up to eleven occupants/subtenants with shared wireless access, and no contraband; Jose Doe was absent and identified as renting a basement bedroom.
- Officers went to Doe’s workplace, met him privately, asked to search his car (he refused), told him they would obtain a warrant and that he could not remove the car while the warrant was sought, but did not tell him he could not leave the building.
- Smith supplemented his affidavit with observations (a blue laptop bag matching occupants’ description was in Doe’s car) and obtained a search warrant for the vehicle and any computers; the laptop was previewed and no contraband was found.
- Doe’s vehicle and bag were inaccessible for about two-and-a-half hours; he was not arrested or charged but lost his job and housing; he sued under 42 U.S.C. § 1983 alleging Fourth Amendment violations (warrant particularity/execution, lack of probable cause for vehicle search, and unlawful detention).
- The district court granted summary judgment for defendants on the merits and on qualified immunity; this appeal challenges portions of that ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity/particularity of residence warrant execution | Warrant targeted a single-family home but officers should have limited the search when they discovered multiple tenants; searching Doe’s rented room violated the Fourth Amendment | Warrant was supported by probable cause for the residence; officers reasonably believed it was a single-family home and were not on notice that searching the room was unlawful | Officers entitled to qualified immunity; no clearly established law put them on notice that searching the rented room under these facts violated the Fourth Amendment |
| Probable cause for vehicle/laptop warrant | Information that Doe had access to Wi‑Fi and had a laptop in a blue bag was insufficient to show probable cause to search his vehicle and computer | Occupants said Doe had wireless access and carried a laptop in a blue bag; officers observed the matching bag in his car—reasonable to seek a warrant; qualified immunity protects reasonable mistakes | Officers entitled to qualified immunity; probable-cause determination was not objectively unreasonable |
| Lawfulness of restricting access to vehicle (detention) | Denying access to his car for ~2.5 hours amounted to an unreasonable seizure of property and unlawful detention | Officers reasonably restrained access while obtaining a warrant; Doe could remain free and was not arrested | Restraint was reasonable under the circumstances and did not violate the Fourth Amendment |
| Qualified immunity on searches and detention | Officers violated clearly established rights, so qualified immunity should not apply | Qualified immunity applies because controlling law did not clearly prohibit their conduct and officers made reasonable judgments | Qualified immunity applies; summary judgment for defendants affirmed (dissent would deny immunity for the searches and detention) |
Key Cases Cited
- Chambers v. Pennycook, 641 F.3d 898 (8th Cir.) (qualified-immunity summary-judgment standards)
- Groh v. Ramirez, 540 U.S. 551 (2004) (warrant particularity requirement)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity framework)
- United States v. Perez, 484 F.3d 735 (5th Cir.) (warrant execution when additional occupants discovered)
- United States v. White, 416 F.3d 634 (7th Cir.) (unit-specificity when building contains multiple units)
- Messerschmidt v. Millender, 565 U.S. 535 (2012) (protection for reasonable but mistaken judgments under qualified immunity)
- Ashcroft v. al‑Kidd, 563 U.S. 731 (2011) (scope of qualified immunity)
- Morris v. Lanpher, 563 F.3d 399 (8th Cir.) (plaintiff burden to show intentional or reckless affidavit falsehoods)
- Illinois v. McArthur, 531 U.S. 326 (2001) (temporary restriction while obtaining a warrant may be reasonable)
- Maryland v. Garrison, 480 U.S. 79 (1987) (validity of warrant and reasonableness of execution when premises' structure differs from warrant)
- United States v. Williams, 917 F.2d 1088 (8th Cir.) (limiting searches when multiple units discovered)
- United States v. Geraldo, 271 F.3d 1112 (D.C. Cir.) (search-limitation principles for multi-unit buildings)
- Jacobs v. Chicago, 215 F.3d 758 (7th Cir.) (officer duties when executing warrants in subdivided dwellings)
- Place v. United States, 462 U.S. 696 (1983) (limits on prolonged seizures of property)
- Malley v. Briggs, 475 U.S. 335 (1986) (objective unreasonableness standard for warrants and immunity)