United States v. Infante
701 F.3d 386
| 1st Cir. | 2012Background
- Infante called 911 for a propane explosion and injury; authorities responded and observed his extensive wounds and suspect explosion origin inside the residence.
- Firefighters entered Infante’s home without a warrant after observing blood trails, a hissing sound, and other indicators, and found marijuana plants and pipe bombs in the cellar.
- The entry occurred under the emergency doctrine, with the government contending an ongoing danger from a potential secondary explosion.
- Infante was later interviewed at a hospital by fire marshal investigators and a Maine Drug Enforcement Agency agent without Miranda warnings; the interviews were non-custodial in nature.
- Infante provided statements about the explosion and later about extracting pyrotechnic powder from snap pops; the government sought to introduce these as evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless home entry/search was justified | Infante | Infante | Emergency doctrine supports warrantless entry |
| Whether plain-view seizure was permissible | Infante | Infante | Plain-view seizure valid under emergency rationale |
| Whether hospital interviews were custodial and required Miranda warnings | Infante | Infante | Not custodial; no Miranda warnings required |
| Whether Infante’s invocation of rights during noncustodial questioning was binding | Infante | Infante | Invocations not applicable in noncustodial setting |
| Whether the statements were suppressible fruits of improper entry | Infante | Infante | Statements not suppressed; admissible |
Key Cases Cited
- Michigan v. Tyler, 436 U.S. 499 (U.S. 1978) (continuing danger allows post-fire entry for investigation)
- United States v. Beaudoin, 362 F.3d 60 (1st Cir. 2004) (emergency doctrine requires reasonable basis to believe emergency exists)
- Martins, 413 F.3d 139 (1st Cir. 2005) (emergency doctrine considerations; danger to life or property)
- United States v. Clifford, 464 U.S. 287 (U.S. 1984) (post-fire searches require administrative warrant absent exigent circumstances)
- Oliver v. United States, 466 U.S. 170 (U.S. 1984) (curtilage/entry considerations and initial observations)