United States v. DANTZLER
2:23-cr-00029
E.D. Pa.May 7, 2025Background
- Lance Ryan was charged with multiple federal offenses related to robbery affecting interstate commerce and firearms violations, in connection to a string of robberies in Philadelphia during 2022.
- Central to the case was an October 4, 2022, armed robbery of a Dollar General store, where a GPS tracker in the stolen cash led police to suspects, including Ryan's codefendants.
- Text messages and phone calls from Ryan to a codefendant, sent immediately after the robbery, linked him to the crime.
- Law enforcement obtained and executed several warrants—two federal and one state—for searches and arrests related to Ryan based on surveillance, eyewitness, and forensic evidence.
- Ryan filed a motion to suppress evidence from these warrants, arguing they lacked probable cause and violated his Fourth Amendment rights.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Expectation of privacy at 6845 Ogontz Ave. | No right for Ryan to suppress | Warrant lacked probable cause | No standing—Ryan had no privacy interest |
| Probable cause for Nov. 18, 2022 federal cell data warrant | Affidavit showed criminality | No evidence of criminality | Substantial basis for probable cause |
| Probable cause for Jan. 3, 2023 federal arrest warrant | Affidavit tied Ryan to crime | Affidavit lacked probable cause | Probable cause established |
| Probable cause for Jan. 4, 2023 search of Ryan’s phone | Affidavit showed links to robbery | No evidence of involvement | Probable cause established |
| Need for an evidentiary hearing on suppression motion | Motion not specific or factual | Evidence/facts are disputed | No hearing warranted |
Key Cases Cited
- Rakas v. Illinois, 439 U.S. 128 (1978) (burden is on movant to prove reasonable expectation of privacy in searched place)
- Steagald v. United States, 451 U.S. 204 (1981) (Fourth Amendment does not allow vicarious assertion of privacy)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause based on totality of circumstances)
- United States v. Miknevich, 638 F.3d 178 (3d Cir. 2011) (substantial basis review of magistrate’s probable cause determination)
- Carroll v. United States, 267 U.S. 132 (1925) (defining probable cause as reasonable ground for belief in guilt)
- United States v. Christine, 687 F.2d 749 (3d Cir. 1982) (suppression under Fourth Amendment exclusionary rule)