United States v. Hendrix
2011 U.S. App. LEXIS 25167
| 10th Cir. | 2011Background
- An informant provided specific, self-inculpatory details about Keith Hendrix selling methamphetamine from Room 327 at Extended Stay America.
- The informant described Hendrix's physical appearance, the room location, and methamphetamine contents, and he was found with meth and paraphernalia on the day of the tip.
- Officers corroborated the motel’s layout, confirmed Room 327 on the north side, and observed activity after identifying themselves as police officers.
- Upon contacting the door, sounds of movement and a flushing toilet suggested attempts to destroy evidence, justifying a warrantless entry.
- Officers opened the door, saw Hendrix-like individuals, and observed meth, bags, a scale, and a video monitor in plain view inside the room.
- A search warrant issued the next day led to seizure of additional drugs, money, firearms, ammunition, and documents linking to Hendrix.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for the motel room search | Hendrix asserts insufficient probable cause from the informant tip. | Hendrix contends the tip alone could not establish probable cause. | Probable cause supported by totality of circumstances. |
| Exigent circumstances justification for entry | Hendrix argues the officers created the exigency via conduct violating the Fourth Amendment. | Hendrix relies on bad-faith creation of exigency; the entry was improper. | Exigent circumstances justified entry; King controls, precluding bad-faith analysis. |
Key Cases Cited
- United States v. Polly, 630 F.3d 991 (10th Cir. 2011) (standard of review for suppression rulings)
- United States v. Parra, 2 F.3d 1058 (10th Cir. 1993) (motel guests protected from warrantless entries)
- Brigham City v. Stewart, 547 U.S. 398 (U.S. 2006) (exigent-circumstances doctrine for destruction of evidence)
- United States v. Quezada-Enriquez, 567 F.3d 1228 (10th Cir. 2009) (totality of the circumstances in informant reliability)
- United States v. Gates, 462 U.S. 213 (U.S. 1983) (probable-cause standard for informant tips)
- United States v. Artez, 389 F.3d 1106 (10th Cir. 2004) (corroboration of informant information by officers)
- United States v. Carr, 939 F.2d 1442 (10th Cir. 1991) (exigent circumstances supported by evidence destruction concern)
- United States v. Cruz-Mendez, 467 F.3d 1260 (10th Cir. 2006) (knock and talk permissible outside a closed motel door)
- Kentucky v. King, U.S. 131 S. Ct. 1849 (U.S. 2011) (police may enter to prevent destruction of evidence if no warrant or violation precedes entry)