United States v. Fahrenkrug, 1:24-cr-00170

Defendant Danny Fahrenkrug moved to suppress statements made to police during his arrest in September 2022, as well as physical evidence seized from subsequent searches of his residence in September 2022 and August 2023.
Police arrested Fahrenkrug at his home based on a felony domestic violence stalking warrant. During the encounter, officers, with Fahrenkrug's invitation, entered the residence and observed firearms and ammunition in plain view.
A search warrant for his home issued later that day led to the seizure of firearms. A separate August 2023 search warrant, based on narcotics and firearms activity claims, led to the discovery of additional contraband during that search.
Fahrenkrug was indicted on counts related to possession of firearms and ammunition by a prohibited person and possession with intent to distribute methamphetamine, among others.
The parties agreed to submit the motions to suppress on the briefs without an evidentiary hearing. The government opposed all suppression motions.

Issue	Defendant's Argument	Government's Argument	Held
Suppression of post-arrest statements (Miranda violation)	Statements were obtained while in custody without Miranda advisement, and police overbore his free will.	No custodial interrogation; statements were volunteered by Fahrenkrug, not in response to police questioning; statements were voluntary.	DENIED: No interrogation or coercion found; statements voluntary and admissible.
Suppression of physical evidence: September 2022 search	Entry into home and observation of firearms/ammunition was nonconsensual and unconstitutional, tainting the search warrant.	Fahrenkrug voluntarily consented to officers entering his home; items seen in plain view provided lawful basis for warrant.	DENIED: Consent was voluntary and plain view applied; warrant was valid.
Suppression of physical evidence: August 2023 search	No substantial nexus between alleged criminal activity and his home, so search lacked probable cause.	Ample probable cause due to multiple criminal nexus facts, including surveillance, statements, and prior criminal activity linked to the home.	DENIED: Affidavit showed sufficient nexus and probable cause for the warrant.

Miranda v. Arizona, 384 U.S. 436 (Miranda warnings required for custodial interrogation; absence generally renders custodial confessions inadmissible)
Rhode Island v. Innis, 446 U.S. 291 (Defines interrogation as express questioning or its functional equivalent)
Schneckloth v. Bustamante, 412 U.S. 218 (Consent is an exception to the warrant requirement; voluntariness determined by totality of circumstances)
Illinois v. Gates, 462 U.S. 213 (Probable cause is based on a fair probability under the totality of the circumstances)
Soldal v. Cook Cnty., 506 U.S. 56 (Fourth Amendment protects against unreasonable searches and seizures)