United States v. Echevarria-Rios, 746 F.3d 39

Early morning shooting left victim Daniel Nelson dead; defendant Hiram Echevarría-Ríos transported Nelson to hospital and was later interviewed by police.
Investigators learned the car Echevarría-Ríos used was a reported stolen Avis rental; Agent Bernice Rosario initiated a summons process and later obtained a state arrest warrant after a probable-cause hearing.
Police received a tip that Echevarría-Ríos was at his mother's house and armed; officers brought a copy of the warrant, obtained consent from his sister to enter, and found him asleep on a bunk bed.
Officers awakened and detained him with guns drawn; after Miranda warnings he admitted a gun was under his pillow and officers recovered a pistol, forming the basis for a federal felon-in-possession charge.
Puerto Rico court later held the state warrant defective because Rosario had never served the summons as required by state procedure; Echevarría-Ríos moved to suppress the gun in federal court on Fourth Amendment and Miranda grounds, which the district court denied.
On appeal, the First Circuit affirmed conviction, holding suppression unnecessary under the good-faith exception to the exclusionary rule (Herring framework); Miranda challenge was not pressed on appeal and thus waived.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of seizure/search incident to arrest	Evidence seized should be suppressed because state arrest warrant was invalid	Officers relied on a facially valid warrant; seizure was pursuant to that warrant	Suppression not required under good-faith exception; officers acted in objectively reasonable reliance
Applicability of Herring good-faith exception	N/A (argued suppression)	Herring permits admission if error not deliberate/reckless/grossly negligent	Herring controls; officers' conduct not culpable enough to require exclusion
Miranda sufficiency of statement about gun	Statement should be suppressed as involuntary/waived improperly	Miranda warnings were given before question; no evidence defendant failed to understand rights	Issue waived on appeal; record shows Miranda warnings given and understood
Standard of review for suppression denial	N/A	Appellate review: legal issues de novo, factual findings for clear error	Court applied bifurcated standard and affirmed district court

Herring v. United States, 555 U.S. 135 (good-faith exception where error not deliberate, reckless, or grossly negligent)
United States v. Leon, 468 U.S. 897 (established good-faith exception to exclusionary rule)
United States v. Rojas-Tapia, 446 F.3d 1 (1st Cir.) (bifurcated standard of review for suppression rulings)
United States v. Diehl, 276 F.3d 32 (1st Cir.) (government bears burden to show officers acted in good faith)
United States v. Thomas, 736 F.3d 54 (1st Cir.) (application of Herring and exclusionary-rule analysis)
United States v. Jiminez, 498 F.3d 83 (1st Cir.) (issues not adequately raised on appeal are waived)