United States v. Hampton, 24-2805

A jury convicted Danielle D. Hampton of maintaining a drug-involved premises under 21 U.S.C. § 856(a)(1). 1
The district court sentenced Hampton to 24 months’ imprisonment and three years’ supervised release. 2
Hampton moved to suppress phones and firearms seized during execution of a search warrant at her home. 3
The district court denied suppression, finding the warrant authorized cell phones and the firearms were in plain view. 4
On appeal, Hampton challenged the search, the sufficiency of the evidence, and the unpronounced supervised-release conditions. 5
The Second Circuit affirmed in part and remanded in part for supervised-release proceedings under Maiorana. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did officers flagrantly disregard the warrant when searching Hampton’s home? 7	Hampton said the team searched “blind” and acted contemptuously toward the warrant.	The government said the warrant authorized the seizures and any error was not flagrant.	No; the warrant authorized the seizures and suppression of all evidence was unwarranted. 8
Was the search unreasonable because officers did not read the warrant? 9	Hampton argued searching without reading the warrant made the search unconstitutional.	The government relied on officers’ prior review and knowledge of the warrant’s scope.	No; the search remained reasonable under Armstrong. 10
Was the evidence sufficient to convict Hampton under § 856(a)(1)? 11	Hampton argued the government proved only isolated sales, not a drug-purpose residence.	The government pointed to drugs, packaging materials, firearms, and Hampton’s ties to the premises.	Yes; a rational jury could find she knowingly used the premises for drug activity. 12
Must the case be remanded because supervised-release conditions were not orally pronounced? 13	Hampton argued the thirteen standard conditions were never pronounced or incorporated.	The government conceded Maiorana required remand.	Yes; limited remand is required to address the conditions. 14

United States v. Ganias, 824 F.3d 199 (2d Cir. 2016) (suppression rulings are reviewed de novo for legal issues and clear error for facts 15)
United States v. Matias, 836 F.2d 744 (2d Cir. 1988) (items outside a valid warrant are normally suppressed individually, not by blanket suppression 16)
United States v. Shi Yan Liu, 239 F.3d 138 (2d Cir. 2000) (blanket suppression applies only for flagrant disregard of the warrant 17)
United States v. Armstrong, 406 F. App'x 500 (2d Cir. 2010) (failure to read a warrant does not necessarily make a search unreasonable 18)
Massachusetts v. Sheppard, 468 U.S. 981 (U.S. 1984) (officers need not proofread a warrant if they reasonably rely on it 19)
United States v. Zhong, 26 F.4th 536 (2d Cir. 2022) (sufficiency review asks whether any rational juror could convict beyond a reasonable doubt 20)
United States v. Facen, 812 F.3d 280 (2d Cir. 2016) (§ 856(a)(1) is satisfied by knowing use of premises for drug distribution or packaging 21)
United States v. Long, 678 F. App'x 31 (2d Cir. 2017) (drug paraphernalia and firearms supported a § 856 conviction 22)
United States v. Maiorana, 153 F.4th 306 (2d Cir. 2025) (non-mandatory supervised-release conditions must be pronounced or incorporated at sentencing 23)