United States v. Angela Garges, 46 F.4th 682

Officers executed a felony arrest warrant for Jason Byers at a Best Western hotel room (Room 246) where Byers was staying with Angela Garges.
Garges opened the door, was escorted out of the room, and officers summoned Byers; officers were positioned at the doorway and at least one officer crossed the threshold while effecting the arrest.
After Byers was secured, officers asked if anyone else was inside; Garges said a ten‑month‑old baby was in the room.
Officers conducted a brief protective sweep, located the baby and drug paraphernalia in plain view, arrested Garges for possession and child endangerment, and took the baby into protective custody.
Garges admitted there was methamphetamine in the room; police obtained search warrants for the room and Garges’s phone and seized inculpatory evidence.
Garges moved to suppress as the product of an unlawful warrantless entry; the district court denied suppression (reasoning Buie sweep justified), she entered a conditional guilty plea, and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of protective sweep under Buie	No specific and articulable facts showing a person posing danger was in the room, so sweep unlawful	Buie authorizes cursory inspection of adjoining spaces or broader sweep if articulable facts suggest danger	Sweep was reasonable as an inspection of spaces immediately adjoining the place of arrest under Buie
Whether entry crossed threshold unlawfully	Entry into room for sweep was warrantless and thus unconstitutional	Officers had authority to enter under the arrest warrant and at least one officer crossed threshold during arrest	Because officers entered under the warrant and were positioned at the doorway, the sweep did not constitute an unlawful entry
Admissibility of evidence in plain view and from subsequent warrant	Evidence was fruit of unlawful search and should be suppressed	Evidence was observed in plain view during a lawful sweep and supported a subsequent warrant	Plain‑view observations were lawful and supported the warrant; evidence admissible
Alternate caretaking justification (baby)	The presence of the baby does not retroactively legalize an unlawful sweep	Officers could alternatively act under community‑caretaker authority upon learning a baby was inside	Court relied on Buie justification and did not need to decide the caretaking basis, but government raised it as an alternative

Maryland v. Buie, 494 U.S. 325 (1990) (establishes protective‑sweep doctrine: cursory inspection of adjoining spaces and broader sweeps on articulable facts of danger)
United States v. McCoy, 200 F.3d 582 (8th Cir. 2000) (courts may consider undisputed facts about threshold position when assessing reasonableness of a sweep)
United States v. Calhoun, 49 F.3d 231 (6th Cir. 1995) (entry under warrant distinguishes lawful threshold entry from unlawful warrantless entry)