877 F.3d 794
8th Cir.2017Background
- At 7:16 a.m., Carol Bak called 911 saying Quarterman, her daughter's boyfriend, had a gun on his waist and had a heated verbal altercation while making her daughter Christina move out.
- Officers arrived at 7:36 a.m.; Carol repeated the report and said Christina was inside.
- At ~7:38 a.m. officers knocked, Christina opened the door; they saw packed bags and Quarterman on the sofa making quick movements.
- Officers announced they would come in, entered without a warrant to control the situation, ordered Quarterman to stand and turn; they observed a holstered handgun on his right side and seized it.
- The gun was later found to be stolen; Quarterman was charged under 18 U.S.C. § 922(g)(1).
- The district court suppressed the gun and derivative evidence as an unconstitutional warrantless entry/search; the government appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers’ warrantless entry/search into home was justified by exigent circumstances | Quarterman: entry violated Fourth Amendment; no exigency or probable cause | Government: officers reasonably believed Christina (and others) were in danger because Quarterman was armed and acting aggressively | Reversed: entry and limited search were objectively reasonable under emergency-aid/officer-safety exigency |
| Whether probable cause was required in addition to exigency | Quarterman: district court erred in finding no probable cause and required it for lawful entry | Government: exigent-circumstances/emergency-aid doctrine does not always require probable cause | Held: probable cause not required when officers have objectively reasonable basis to take immediate action to protect safety |
| Whether officers could detain/search Quarterman and seize the weapon once inside | Quarterman: seizure/search of person and gun unlawful without warrant/probable cause | Government: limited search/seizure to secure a weapon and ensure safety was justified | Held: ordering stand/turn and temporarily seizing weapon was reasonable and permitted under exigency and plain-view/weapon-seizure principles |
| Scope/duration of search/detention incident to exigency | Quarterman: any search beyond protective sweep exceeded permissible scope | Government: actions were brief and tailored to neutralize immediate threat | Held: brief, limited measures to control situation and secure weapon were lawful |
Key Cases Cited
- United States v. Roberts, 824 F.3d 1145 (8th Cir. 2016) (exigent-entry facts supporting warrantless entry to control dangerous situation)
- Michigan v. Fisher, 558 U.S. 45 (2009) (emergency-aid exigency requires only an objectively reasonable basis that immediate aid is needed)
- Brigham City v. Stuart, 547 U.S. 398 (2006) (exigent circumstances justify warrantless entry to protect life or avoid serious injury)
- United States v. Uscanga-Ramirez, 475 F.3d 1024 (8th Cir. 2007) (limited in-home search to secure a gun justified by officer safety)
- United States v. Kuenstler, 325 F.3d 1015 (8th Cir. 2003) (objective officer-safety standard for exigent entries)
- United States v. Henderson, 553 F.3d 1163 (8th Cir. 2009) (domestic-violence context can justify exigent entry to secure weapons)
- Kleinholz v. United States, 339 F.3d 674 (8th Cir. 2003) (probable cause requirement applied in meth-lab exigency contexts)
- Burke v. Sullivan, 677 F.3d 367 (8th Cir. 2012) (brief detention after lawful exigent entry may be reasonable)