United States v. Alejandro Barron-Soto
820 F.3d 409
| 11th Cir. | 2016Background
- Barron-Soto and Hernandez were convicted at a joint trial of conspiracy to distribute and possess with intent to distribute 500g+ methamphetamine, possession with intent to distribute 500g+ meth, and Barron-Soto’s illegal reentry after deportation.
- A warrantless search of Hernandez and Barron-Soto’s cell phones occurred at arrest; a subsequent warrant was sought for their phones’ contents.
- The district court denied suppression, applying exigent-circumstance justification due to potential data wipe, and the independent-source issue was remanded for limited fact-finding.
- On remand, the district court found the warrant was not prompted by the initial warrantless search, and the appellate panel reviewed de novo.
- The panel ultimately affirmed the convictions, upholding admissibility of the phone data under the independent-source doctrine and rejecting challenges under Rule 404(b) and sufficiency of evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Independent-source admissibility after Riley challenge | Hernandez/Barron-Soto: Riley requires suppression of warrantless search | Government: independent source preserves admissibility if warrant would have been obtained anyway | Independent source admissible; suppression affirmed no. |
| Rule 404(b) admissibility of prior drug conviction | Prior conviction unfairly prejudicial and dissimilar | Prior act probative of intent in conspiracy/possession | Court did not abuse discretion; prior conviction admitted. |
| Sufficiency of evidence for conspiracy and possession with intent to distribute | No direct proof of agreement or knowledge; insufficient | Circumstantial evidence supports guilt | Sufficient evidence; reasonable jury could find guilt beyond reasonable doubt. |
| Probable cause to stop Barron-Soto’s vehicle | No probable cause for stop | Probable cause existed based on transport and surrounding facts | Probable cause supported stop. |
Key Cases Cited
- Nix v. Williams, 467 U.S. 431 (U.S. 1984) (independent source doctrine framework; exclusionary-rule exception)
- Noriega v. United States, 676 F.3d 1252 (11th Cir. 2012) (two-part independent-source analysis; prompting question is a factual inquiry)
- Murray v. United States, 487 U.S. 533 (U.S. 1988) (prompting to seek a warrant is a factual question; deference to factual findings)
- Riley v. California, 134 S. Ct. 2473 (U.S. 2014) (searches of cell phones incident to arrest require warrants absent exigencies)
- Isnadin v. United States, 742 F.3d 1278 (11th Cir. 2014) (elements of conspiracy and possession with intent to distribute; circumstantial proof permissible)
- Cochran v. United States, 683 F.3d 1314 (11th Cir. 2012) (probable cause and evidence standards for drug-distribution cases)
- Chavez v. United States, 204 F.3d 1305 (11th Cir. 2000) ( Rule 404(b) admissibility factors; probative value vs. prejudice)
- Cardenas v. United States, 895 F.2d 1338 (11th Cir. 1990) (prior drug-offense evidence in conspiracy cases; probative value favored over prejudice)
- Tobin v. United States, 923 F.2d 1506 (11th Cir. 1991) (probable cause and stop framework)