Ronald Shinstock v. State of Mississippi, 220 So. 3d 967

Rankin County deputies used a confidential informant, William Valentine, to perform a controlled buy of methamphetamine from Ronald Shinstock; Valentine wore a hidden camera and used $260 in marked buy money.
After Valentine completed the purchase inside Shinstock’s home, officers met Valentine, recovered the drugs, then went to Shinstock’s house and arrested him without a recorded suppression challenge at trial.
Officers found $260 in bills matching the marked buy money on Shinstock and digital scales in the master bedroom; lab testing confirmed 2.8 grams of methamphetamine and county records showed the sale occurred within 1,500 feet of a church.
At trial, the State introduced the drugs and scales without objection; McAlpin testified about finding the marked bills on Shinstock.
Jury convicted Shinstock of selling >2g but <10g methamphetamine near a church; as a habitual offender he received the statutory maximum forty-year sentence.
On appeal Shinstock raised two claims: (1) warrantless entry/arrest violated the Fourth Amendment, and (2) ineffective assistance of counsel for failing to move to suppress.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry/arrest into home	Shinstock: officers entered home and arrested him without a warrant or exigent circumstances; evidence is "fruit of the poisonous tree" and should be excluded	State: Shinstock forfeited the Fourth Amendment claim by not moving to suppress or object at trial; record undeveloped so no plain error shown	Forfeited; no plain error — appellate record insufficient to evaluate legality of entry/search; claim denied
Ineffective assistance for not filing suppression motion	Shinstock: counsel was constitutionally ineffective for failing to file a motion to suppress evidence from the warrantless arrest	State: record lacks the factual development needed to assess ineffective-assistance claim; failure to file suppression motion alone is not per se ineffective assistance	Denied on direct appeal for insufficient record; claim preserved for post-conviction relief

Payton v. New York, 445 U.S. 573 (warrantless home arrests presumptively unreasonable)
Welsh v. Wisconsin, 466 U.S. 740 (government bears burden to show exigent circumstances for warrantless entry)
Murray v. United States, 487 U.S. 533 (exclusionary-rule principles regarding "fruit of the poisonous tree")
Olano v. United States, 507 U.S. 725 (forfeiture of issues not raised at trial)
Kimmelman v. Morrison, 477 U.S. 365 (failure to file suppression motion is not per se ineffective assistance)
Walker v. State, 913 So. 2d 198 (Fourth Amendment challenges forfeited without trial objection or suppression motion)
Wilcher v. State, 863 So. 2d 776 (direct-appeal ineffective-assistance claims often inappropriate due to undeveloped record)