United States v. Anthony Dejuan Williams, 2017 U.S. App. LEXIS 18202

FBI surveilled a large-scale cocaine conspiracy; intercepted calls tied Anthony Williams to a kilogram of cocaine and tracked activities to 344 Sun Valley Road.
Property included a main house and a separate outbuilding ~20 feet away that appeared habitable (windows, doors, garage door); public records listed 344 Sun Valley Road as Williams’s probable address.
On Oct. 21, 2015, FBI executed a coordinated arrest warrant at about 6:00 a.m.; agents planned simultaneous entries of the main house and the outbuilding because they did not know where Williams lived or whether others were present.
Agents knocked and breached both structures nearly simultaneously; Williams was found and arrested in the main residence; the outbuilding was unoccupied but contained drug paraphernalia and a drug press in plain view.
Agents obtained a search warrant based on the plain-view evidence and found substantial quantities of drugs, presses, diluting agents, weapons, and a deed linking Williams to the property.
Williams moved to suppress the outbuilding evidence; district court denied the motion. On appeal Williams argued the outbuilding entry was unreasonable and (for the first time) that execution at “approximately” 6:00 a.m. violated Rule 41.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether entry into outbuilding was lawful as entry incident to an arrest warrant	Entry was unreasonable because agents lacked a basis to believe Williams lived in or was present in the outbuilding	Agents reasonably believed Williams lived on the property (main house or outbuilding) and might be present, supporting simultaneous entry	Entry was reasonable: totality of facts supported belief Williams lived on property and might be inside either structure, so entry incident to arrest was lawful
Whether search of outbuilding qualified as a protective sweep	Outbuilding was separate and distant; no reasonable suspicion of dangerous persons inside	Proximity, property layout, noise suggesting drug activity, multiple cars, and timing gave reasonable suspicion of others who could pose danger	Valid protective sweep: articulable facts and inferences supported reasonable suspicion to sweep the outbuilding
Whether executing the arrest warrant at “approximately” 6:00 a.m. invalidated the warrant under Rule 41	Execution before 6:00 a.m. (if true) violated Rule 41 and required suppression	Even if there was minor technological/noncompliance, no prejudice or intentional disregard; Fourth Amendment has no strict time limit	No suppression: technical Rule 41 issue (if any) did not warrant suppression absent prejudice or deliberate violation; no constitutional violation shown

United States v. Bervaldi, 226 F.3d 1256 (11th Cir. 2000) (arrest-warrant entry into dwelling requires reasonable belief suspect lives there and is present)
United States v. Magluta, 44 F.3d 1530 (11th Cir. 1995) (totality of circumstances and common-sense inferences inform presence-at-home determinations)
Maryland v. Buie, 494 U.S. 325 (1990) (protective-sweep doctrine; cursory inspection of places where a person may be found)
United States v. Smith, 459 F.3d 1276 (11th Cir. 2006) (plain-view seizure following a lawful entry can justify a subsequent search warrant)
Payton v. New York, 445 U.S. 573 (1980) (arrest warrants carry limited authority to enter a suspect’s dwelling)
United States v. Gerber, 994 F.2d 1556 (11th Cir. 1993) (Rule 41 noncompliance warrants suppression only for prejudice or intentional disregard)