United States v. Dustin Caya
956 F.3d 498
| 7th Cir. | 2020Background
- On June 1, 2018, officers found Melissa Thomas passed out in a car with a meth pipe; she later told police she and her live-in boyfriend, Dustin Caya, obtained and shared meth and that Thomas’s children were at home.
- Officers went to Caya’s home for a welfare check; Caya appeared intoxicated and officers knew he was on Wisconsin extended supervision (subject to Wis. Stat. § 302.113(7r), Act 79).
- Relying on Act 79 (which permits searches of persons, residences, or property of those on extended supervision upon reasonable suspicion of criminal activity or supervision violations), officers searched the home, found a one‑year‑old, large quantities of methamphetamine, drug paraphernalia, cash, and multiple loaded firearms.
- A federal grand jury indicted Caya on meth distribution and firearms charges; he moved to suppress evidence as an unconstitutional warrantless search; the district court denied the motion.
- Caya pleaded guilty (reserving the right to appeal the suppression ruling) and was sentenced to concurrent 78‑month terms; he appealed the denial of suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Act 79 searches (warrantless searches of those on extended supervision based on reasonable suspicion) violate the Fourth Amendment | Caya: Extended supervision searches cannot be justified under Griffin/Knights/Samson; warrantless searches of extended‑supervision subjects require greater protection (i.e., probable cause or special‑needs limits) | Government: Extended supervision is essentially parole; supervision diminishes privacy expectations and the state’s interest in supervision/reduction of recidivism justifies reasonable‑suspicion searches under Act 79 | Court: Act 79 searches are constitutional; Samson controls because Wisconsin extended supervision functions like parole, so reasonable‑suspicion searches are permissible |
| Whether Wisconsin’s extended supervision is more like probation (greater privacy) or parole (diminished privacy) | Caya: Extended supervision resembles probation, so greater privacy and limits should apply | Government: Extended supervision is judicially imposed parole (part of bifurcated sentence), so privacy expectations are weak | Court: Extended supervision is effectively parole; privacy is diminished, supporting Act 79’s constitutionality |
| Whether Knights/Samson required explicit notice/consent for law‑enforcement searches to be upheld | Caya: Knights/Samson are fact‑bound and relied on notice/conditions | Government: Knights/Samson did not rest on consent; they analyze diminished privacy and government interests | Court: Knights and Samson do not depend on a consent rationale; their reasoning supports upholding Act 79 searches |
| Whether Fourth Circuit’s Hill (invalidating warrantless home searches of supervised‑release subjects) compels a different result | Caya: Hill suggests absence of statutory/condition authorization makes such searches unlawful | Government: Hill is distinguishable because Act 79 expressly authorizes law‑enforcement searches on reasonable suspicion | Court: Hill is inapposite; Caya conceded statutory authorization, so Hill does not help him |
Key Cases Cited
- Griffin v. Wisconsin, 483 U.S. 868 (1987) (probationer home search upheld under special‑needs rationale because supervision requires close monitoring)
- United States v. Knights, 534 U.S. 112 (2001) (probationer’s expectation of privacy diminished; law‑enforcement search reasonable under totality‑of‑circumstances with reasonable suspicion)
- Samson v. California, 547 U.S. 843 (2006) (parolees have very limited privacy expectations; suspicionless searches of parolees permissible under Fourth Amendment)
- New Jersey v. T.L.O., 469 U.S. 325 (1985) (describes special‑needs framework for departures from usual warrant/probable‑cause requirements)
- United States v. Hill, 776 F.3d 243 (4th Cir. 2015) (invalidated warrantless home searches of supervised‑release subjects where no statutory/condition authorized warrantless law‑enforcement searches)