972 F.3d 1230
11th Cir.2020Background
- Fugitive task force obtained arrest warrants for two armed robbery suspects (Hines and Mock) and learned Hines’s girlfriend, Nakita Rogers, had checked into a Country Inn & Suites with at least one other person.
- Officers surveilled the hotel; several people entered, some left; team split to stop a departing vehicle while another team went to the hotel room believed to be associated with the suspects.
- At the slightly ajar door an officer encountered Darrius Mastin (not a warrant subject); officers ordered room occupants to kneel and crawl into the hallway one-by-one; as Mastin crawled out a 9mm fell from his waistband.
- Officers seized the firearm, detained Mastin, and, during a sweep, observed three handguns in plain view; records showed Mastin was a felon on probation.
- Mastin was indicted for being a felon in possession, moved to suppress the firearm and challenged the legality of the entry and his detention; the magistrate and district court denied suppression and limited certain cross-examination areas; Mastin was convicted and appealed.
Issues
| Issue | Mastin's Argument | United States' Argument | Held |
|---|---|---|---|
| 1. Whether officers lawfully entered the hotel room to execute arrest warrants when they lacked absolute certainty the suspects were inside | Entry unlawful because officers were not certain Hines/Mock were present | Entry lawful under Payton/Bervaldi: arrest warrants carry limited authority to enter a dwelling when officers reasonably believe the suspect resides there and is present | Entry was reasonable; officers had a reasonable belief the room was the suspects’ dwelling and that at least one was inside, so Payton/Bervaldi permit entry |
| 2. Whether ordering an innocent bystander to crawl out of the room was an unreasonable seizure under the Fourth Amendment | Seizure unreasonable as Mastin was an innocent, non-suspect bystander and the manner of detention was excessive | Brief detention of occupants during execution of warrants is authorized (Summers rationale extended to arrest warrants) and the manner (crawl-out) was reasonable for officer safety | Seizure was reasonable; Summers rationale applies to arrest-warrant executions and the method was not an unreasonable infringement |
| 3. Whether the district court violated Mastin’s Sixth Amendment right by limiting cross-examination of officers (e.g., whether they had a search warrant, equipment, other guns, pistol permits) | Limits prevented probing officer bias/credibility and undermined Mastin’s theory that officers planted/contrived the gun evidence | Questions were legally irrelevant or cumulative; issues about legality of entry already decided; limits were within court’s discretion to avoid confusion | No Sixth Amendment violation; district court acted within its discretion because proposed questions were marginally relevant, cumulative, or risked confusing issues |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (arrest warrant implicitly authorizes limited entry into dwelling when officer reasonably believes suspect is inside)
- Michigan v. Summers, 452 U.S. 692 (warrant to search carries implicit authority to detain occupants during search)
- Maryland v. Buie, 494 U.S. 325 (protective sweeps allowed during in-home arrests if reasonable belief sweep is necessary for safety)
- Muehler v. Mena, 544 U.S. 93 (evaluating manner of detention—handcuffing—consistent with Summers authorization)
- Brigham City v. Stuart, 547 U.S. 398 (Fourth Amendment reasonableness standard for protective action to ensure safety)
- Illinois v. Caballes, 543 U.S. 405 (manner of execution of otherwise lawful seizure can violate Fourth Amendment)
- Stoner v. California, 376 U.S. 483 (hotel guests retain Fourth Amendment protections)
- Davis v. Alaska, 415 U.S. 308 (cross-examination central to testing witness credibility)
- United States v. Bervaldi, 226 F.3d 1256 (Eleventh Circuit applying Payton factors for dwelling entry to execute arrest warrants)
- United States v. Magluta, 44 F.3d 1530 (mixed fact-law review standard for suppression rulings and assessment of reasonableness)
- United States v. Maxwell, 579 F.3d 1282 (district court’s broad discretion to limit cross-examination tempered by Confrontation Clause)
- United States v. Garcia, 13 F.3d 1464 (Confrontation Clause satisfied by sufficient cross-examination; further questioning within court’s discretion)