United States v. Butler, 2:22-cr-00007

Andrew Butler was the subject of a 911 call reporting a domestic dispute and the presence of a firearm; he fled the scene before police arrived.
Police tracked Butler to his place of employment, the Altium Packaging facility, where he was working the night shift.
Officers entered the facility without a warrant or consent from the business or its management, believing Butler to be present and armed.
Butler attempted to flee from police inside the facility, was ultimately apprehended, and a gun was recovered in the area where he was arrested; Butler's fingerprints were found on the weapon.
Butler was a convicted felon on probation, subject to a search waiver, and had outstanding warrants at the time of the arrest.
Butler moved to suppress the gun and fingerprint evidence, claiming the entry, search, and seizure violated the Fourth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry into workplace	Butler cannot challenge entry because he lacks a reasonable expectation of privacy in his workplace under the circumstances	Entry was unconstitutional as it was warrantless, without owner consent, and without exigent circumstances	Butler lacked a legitimate expectation of privacy; motion denied
Arrest without a warrant inside private facility	Arrest was supported by probable cause, active warrants, and the search waiver	Arrest inside workplace without warrant was unconstitutional	Lawful; officers had probable cause and authority due to warrants and waiver
Seizure of firearm found on scene	Seizure justified by search waiver and/or abandonment	Seizure was fruit of unconstitutional search; evidence should be excluded	Lawful; justified under waiver or abandonment doctrine
Use of fingerprint evidence as fruit of unlawful search	Evidence lawful; no violation occurred	Fingerprint is fruit of unlawful seizure, must be suppressed	Evidence admissible; no illegal search, so no taint

United States v. Matlock, 415 U.S. 164 (explains preponderance standard at suppression hearings)
Rakas v. Illinois, 439 U.S. 128 (Fourth Amendment expectation of privacy analysis)
Oliver v. United States, 466 U.S. 170 (reasonable expectations of privacy under Fourth Amendment)
Katz v. United States, 389 U.S. 347 (Fourth Amendment protects people, not places)
Minnesota v. Carter, 525 U.S. 83 (commercial premises have diminished expectation of privacy)
California v. Hodari D., 499 U.S. 621 (defining Fourth Amendment seizure)
Samson v. California, 547 U.S. 843 (search waivers for probationers diminish privacy expectations)
United States v. Knights, 534 U.S. 112 (probationers' waiver justifies warrantless searches)