Reynaldo Castillo v. United States
2016 U.S. App. LEXIS 4684
11th Cir.2016Background
- Castillo entered a Florida pretrial intervention (PTI) program after confessing to burglary and related offenses; his PTI agreement barred possession of firearms and allowed unannounced visits and searches by his PTI officer.
- A victim’s advocate (Castillo’s former mother‑in‑law) sent a MySpace photo showing a man resembling Castillo holding a gun and making threats; she reported this to the PTI office.
- PTI Officer Louis Kurtz went to Castillo’s home, knocked for ~15 minutes, Castillo delayed and then denied having guns and objected to a search; Kurtz entered and observed a bolt‑action rifle, cases, ammunition, helmets, and a mask.
- Based on Kurtz’s observations, police obtained a search warrant and seized 13 firearms and >7,000 rounds of ammunition; federal agents later prosecuted and convicted Castillo on multiple firearms and machine‑gun related counts.
- Castillo filed a 28 U.S.C. § 2255 motion asserting ineffective assistance of trial counsel for failing to move to suppress evidence from the initial warrantless search or to dismiss the indictment; the district court denied the motion without an evidentiary hearing.
- The Eleventh Circuit affirmed, holding the warrantless search constitutional (reasonable suspicion + diminished expectation of privacy due to PTI + strong state interests), so counsel’s failure to move to suppress/dismiss was not deficient or prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an evidentiary hearing was required on Castillo’s claim that counsel was ineffective for failing to move to suppress evidence from a warrantless search | Castillo: counsel was ineffective for not moving to suppress/dismiss based on an illegal warrantless entry and search | Government: the warrantless search was reasonable; thus counsel had no obligation to move to suppress and Castillo suffered no prejudice | Denied — no hearing required because the search was constitutional, so no Strickland violation established |
| Whether the warrantless entry/search by the PTI officer violated the Fourth Amendment | Castillo: PTI entry/search was unlawful and its fruits should be suppressed | Government: PTI conditions diminished Castillo’s expectation of privacy; officer had reasonable suspicion based on tip/photo, threats, and Castillo’s behavior | Search was reasonable under totality of circumstances (diminished privacy, strong state interest, reasonable suspicion) |
| Standard of suspicion required to search a PTI participant’s home | Castillo: implied (argued) that higher protection applies absent probable cause/warrant | Government: only reasonable suspicion required given diminished privacy from PTI conditions and state interests | Reasonable suspicion sufficed (analogous to probationer/parolee jurisprudence) |
| Whether counsel’s failure to challenge later state search-warrant validity could support relief | Castillo: raised additional challenge to warrant | Government: COA limited to ineffective-assistance claim about pre‑warrant search; warrant defects outside scope | Court declined to consider warrant‑validity claims beyond the COA’s limited issue |
Key Cases Cited
- Samson v. California, 547 U.S. 843 (2006) (upholding suspicionless searches of parolees and recognizing reduced privacy expectations and strong state interests)
- United States v. Knights, 534 U.S. 112 (2001) (probationer searches reasonable on reasonable suspicion when conditions permit searches and balance favors government)
- Strickland v. Washington, 466 U.S. 668 (1984) (two‑part test for ineffective assistance: deficient performance and prejudice)
- Kimmelman v. Morrison, 477 U.S. 365 (1986) (counsel’s failure to litigate Fourth Amendment claims analyzed under Strickland; if search constitutional, no prejudice)
- United States v. Carter, 566 F.3d 970 (11th Cir. 2009) (upholding reasonable‑suspicion standard for searches of probationers subject to unannounced visits)