United States v. Flores, 888 F.3d 537

DEA task-force trooper Pappas received a tip from a reliable informant (via colleague) that New Yorkers were selling cocaine from the Fairfield Inn in Brunswick, Maine.
Hotel records showed only one cash-paid room (131) registered to a New York address; the front‑desk manager reported frequent visitors and gave a physical description of an occupant.
While surveilling, Pappas observed Flores (matching the description) engage in a brief hand‑to‑hand exchange in a parked car, then count money; he later saw Flores smoking marijuana.
Officers detained and handcuffed Flores outside the hotel (a de facto arrest); a search of his person found cash, keycard, IDs, and phones.
Officers used Flores’s keycard to enter room 131 without a warrant, performed a security sweep (observing cash and a jar of marijuana), then later obtained a warrant based on an affidavit that incorporated the informant tip, manager statements, the observed transaction, and other facts.
Warrant search recovered heroin, many baggies, and a digital scale; Flores pleaded guilty conditionally and appealed the district court’s refusal to suppress the warrant‑search fruits and its finding of probable cause for the arrest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers had probable cause to effect a de facto arrest of Flores in the parking lot	Flores: no probable cause—observations were equivocal (no drugs seen exchanged, cash payments and marijuana use can be innocent)	Government: tip + hotel corroboration + manager description + observed hand‑to‑hand exchange + counting money gave probable cause	Held: Probable cause existed under the totality of circumstances; arrest reasonable and affirmed
Whether evidence from the warrant‑backed search of room 131 must be suppressed because of the earlier unlawful entry	Flores: warrant tainted by knowledge from the illegal entry; independent‑source doctrine does not apply	Government: officers would have sought a warrant independent of the illegal entry; affidavit (minus tainted facts) still established probable cause	Held: Independent source doctrine applies; affidavit, stripped of tainted material, still supported probable cause; fruits of warrant search admissible

Atwater v. City of Lago Vista, 532 U.S. 318 (officer may arrest when probable cause the suspect committed an offense in officer's presence)
District of Columbia v. Wesby, 138 S. Ct. 577 (probable cause assessed by totality of circumstances; courts must avoid isolating innocent explanations)
Illinois v. Gates, 462 U.S. 213 (probable cause is a ‘‘fluid concept’’ assessed under the totality of the circumstances)
Maryland v. Pringle, 540 U.S. 366 (probable cause inquiry considers events leading up to arrest)
Murray v. United States, 487 U.S. 533 (independent source doctrine permits admission when warrant derives from sources independent of prior unlawful entry)
Nix v. Williams, 467 U.S. 431 (societal interest in admitting probative evidence balanced against deterrence of police misconduct)
Florida v. Jardines, 569 U.S. 1 (Fourth Amendment protection for dwellings; hotel rooms treated as temporary dwellings)
Payton v. New York, 445 U.S. 573 (warrant generally required to enter a dwelling to search for evidence)
Riley v. California, 573 U.S. 373 (search‑warrant rule and warrant requirement principles relevant to searches for evidence)
Ornelas v. United States, 517 U.S. 690 (standard of review for mixed questions of law and fact in suppression rulings)
United States v. Patane, 542 U.S. 630 (distinction between Miranda warnings and admissibility of physical evidence from voluntary statements)