United States v. Hamilton, 819 F.3d 503

Background

Dec. 16, 2010: a Malden bank robbery occurred; surveillance and other investigation pointed to Anthony Hamilton. Hamilton became the target of a federal indictment.
Police identified multiple addresses for Hamilton; public records also associated the name Tommy Smith with 16 Harrow Street (Dorchester).
Tommy Smith had an outstanding state arrest warrant (issued Jan. 11, 2011) listing 16 Harrow Street; postal records and various databases showed mail and other records tied to that address.
On Feb. 16, 2011, officers went to 16 Harrow Street intending to execute Tommy Smith’s warrant; resident Amina Smith said Tommy did not live there, but officers entered and found Hamilton, then arrested him.
Residents (including the renter) consented to a search after entry; officers located a firearm and ammunition under a mattress.
Hamilton moved to suppress the evidence; the district court denied the motion, finding officers reasonably believed Tommy Smith resided at and would be present at 16 Harrow Street. Hamilton reserved appeal of the suppression ruling as part of a conditional guilty plea.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officers reasonably believed Tommy Smith resided at 16 Harrow St	Government: records (warrant listing, postal, booking, databases) supported reasonable belief	Hamilton: records undated or stale; young adults often use parents' address; evidence insufficient	Held: Reasonable belief supported by multiple corroborating records and recent postal/warrant info
Whether officers reasonably believed Tommy Smith would be present at time of entry (6 AM)	Government: if resident, presence early morning is reasonable to expect	Hamilton: pole camera showed no positive ID of Tommy entering/exiting, undercutting belief he lived there or would be present	Held: Pole camera was low quality and did not undermine reasonable belief that a resident would be home at 6 AM
Whether pretextual motive invalidates entry based on another’s warrant	Hamilton: district court found possible pretext but argued entry unlawful if pretextual	Government: relied on Tommy Smith warrant to justify entry	Held: Court affirmed that pretextual motive does not invalidate entry if officers reasonably believed warrant subject lived there and would be present
Whether consent to search was involuntary or irrelevant if entry unlawful	Hamilton: earlier argued consents were involuntary and entry invalid	Government: residents consented; entry justified by Smith warrant	Held: On appeal, parties did not press voluntariness; court rested on legality of entry based on reasonable belief in Smith’s residence/presence

Key Cases Cited

Payton v. New York, 445 U.S. 573 (arrest warrant permits entry into suspect's home when officers reasonably believe suspect is inside)
United States v. Graham, 553 F.3d 6 (1st Cir. 2009) (reasonableness of belief that suspect resides at location assessed by totality of records)
United States v. Werra, 638 F.3d 326 (1st Cir. 2011) (reasonable belief standard for entry; burden on defendant to show Fourth Amendment violation)
Solis-Alarcón v. United States, 662 F.3d 577 (1st Cir. 2011) (presence at early morning hour may be reasonably presumed if suspect resides at location)
United States v. Thomas, 429 F.3d 282 (D.C. Cir. 2005) (officers may reasonably infer presence at residence during early hours)
United States v. Bervaldi, 226 F.3d 1256 (11th Cir. 2000) (same principle regarding early-morning presence of residents)