United States v. Dustin Allen Wolff, 830 F.3d 755

Probation officer received tip Wolff (a federal felon on supervised release) may have committed crimes and possessed contraband; his release conditions permitted searches based on evidence of violation.
Officers searched Wolff’s truck and trailer and found drugs and paraphernalia; they then targeted a locked shed on property owned by Wolff’s father, Allen.
Allen acknowledged ownership of the shed but said he did not put the padlock on it and did not have a key; Allen gave inconsistent testimony about consenting to a search.
Officers testified Wolff consented to a search, located bolt cutters, and personally cut off the padlock; officers then searched the shed and seized firearms, ammunition, and other incriminating items.
Wolff moved to suppress the shed evidence arguing a warrant was required; the district court denied the motion, crediting officers’ testimony that both Allen and Wolff consented.
Wolff conditionally pled guilty and appealed the denial of the suppression motion; the Eighth Circuit affirmed.

Issue	Wolff’s Argument	Government’s Argument	Held
Whether officers needed a warrant to search the locked shed	Warrant required; no valid consent for shed search	Consent exception applied: Wolff (and Allen) consented; probation search rules also justify search	Affirmed: officers obtained consent from Wolff (and Allen in testimony), so no Fourth Amendment violation
Whether father’s ownership affects search validity	Allen did not authorize removal of lock; thus no valid third-party consent	Even if Allen didn’t consent, Wolff’s own consent (and conduct cutting lock) suffices	Affirmed: Wolff’s consent independently validated search
Whether district court erred in crediting officers’ testimony	Contends officers’ accounts contradicted by Allen and statement he refused to cut lock	Government points to consistent, credible testimony from three officers and lack of contradictory testimony from Wolff	Affirmed: credibility findings not clearly erroneous; officer testimony essentially uncontradicted
Whether Wolff may invoke Allen’s Fourth Amendment rights	Arguably seeks suppression based on Allen’s lack of consent	Government: defendant cannot assert third party’s Fourth Amendment rights to suppress evidence	Court: Wolff cannot rely on alleged violation of Allen’s rights to obtain suppression

United States v. Knights, 534 U.S. 112 (probation search doctrine supports warrantless searches based on condition of supervised release)
Schneckloth v. Bustamonte, 412 U.S. 218 (valid consent is an exception to the warrant requirement)
Fernandez v. California, 571 U.S. 292 (co-occupant consent and consent principles)
Florida v. Jardines, 569 U.S. 1 (warrant requirement for physical intrusion into constitutionally protected areas)
Riley v. California, 573 U.S. 373 (warrant requirement and exceptions overview)
United States v. Salamasina, 615 F.3d 925 (standard of review for suppression rulings)
United States v. Wallace, 713 F.3d 422 (appellate review standards for suppression denials)
United States v. Bay, 662 F.3d 1033 (appellate standards and suppression law)
United States v. Harper, 787 F.3d 910 (officer testimony can establish consent despite contradictory statements)
United States v. Frencher, 503 F.3d 701 (credibility findings on appeal are virtually unassailable)
United States v. Guel-Contreras, 468 F.3d 517 (credibility and appellate review of factual findings)
United States v. Heath, 58 F.3d 1271 (credibility/clear error discussion)
United States v. Webster, 625 F.3d 439 (only one valid exception to warrant requirement necessary)
United States v. Douglas, 744 F.3d 1065 (limitations on asserting third-party Fourth Amendment rights)