United States v. Cornell Williams, 77 F.4th 1197

911 call reported a shot fired from Apartment 32; caller identified the shooter as a man in a wheelchair.
Officers arrived ~20 minutes later, spoke to witnesses, then knocked; Williams (occupant of Apt. 32) answered and matched the description.
Officers entered to pat down Williams for safety; Williams consented when an officer asked to "look" around to ensure no one else was present.
During a sweep, an officer observed a spent shell casing on the balcony in plain view; questioning ensued and Williams initially denied gun possession but later admitted firing and said the gun was hidden in a kitchen cabinet.
At Williams’s direction, officers retrieved the gun from the cabinet. He was charged under 18 U.S.C. § 922(g)(1); the district court denied his suppression motion, he conditionally pleaded guilty, and appealed.
Standard of review: Fourth Amendment legal issues reviewed de novo; factual findings for clear error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Warrantless entry and pat-down	Entry without a warrant violated the Fourth Amendment	Exigent circumstances justified limited entry and pat-down given a recent shots-fired report and a suspect who matched the description	Entry and pat-down were reasonable under exigent-circumstances precedent
Protective sweep / search of apartment	Any interior sweep required a warrant; consent was not valid	Williams consented when he said "you can do whatever you want," authorizing a protective sweep	Consent was valid; protective sweep lawful
Seizure of shell casing in plain view	Seizure unlawful absent warrant	Shell casing was in plain view during a lawful consented sweep, so seizure was permissible	Plain-view seizure upheld
Retrieval of gun from kitchen cabinet	Officers needed a warrant; cabinet search not justified by exigency	Williams admitted firing and, by words and actions, consented to retrieval of the gun	Retrieval was lawful based on Williams’s clear consent

Kentucky v. King, 563 U.S. 452 (2011) (warrantless home entry is presumptively unreasonable; exceptions exist)
Maryland v. Buie, 494 U.S. 325 (1990) (protective sweep doctrine for officer safety)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (consent negates warrant requirement; voluntariness standard)
Florida v. Jimeno, 500 U.S. 248 (1991) (consent scope judged objectively)
Coolidge v. New Hampshire, 403 U.S. 443 (1971) (plain-view doctrine applied when initial intrusion is justified)
United States v. Valencia, 499 F.3d 813 (8th Cir. 2007) (shots-fired calls can justify warrantless entry to secure scene)
United States v. Vance, 53 F.3d 220 (8th Cir. 1995) (exigent-circumstances exception for officer safety)
United States v. Kuenstler, 325 F.3d 1015 (8th Cir. 2003) (objective-reasonableness test for officer safety searches)