30 F.4th 613
7th Cir.2022Background
- ATF agents were seeking fugitive Ernesto Godinez (wanted for shooting an ATF agent). Cell‑site data placed a phone linked to Godinez near Jose Segoviano’s apartment building; agents surveilled the building and observed Godinez’s girlfriend, Destiny Rodriguez, exit.
- Agents entered the building, mistakenly treated a stairwell as a public area, encountered Segoviano at the top of the stairs, asked permission to search for the fugitive, and conducted an initial sweep; Segoviano was handcuffed and detained during this process.
- After the sweep showed Godinez was not in Segoviano’s apartment, agents kept Segoviano handcuffed, brought him into his apartment, and questioned him (6–7 agents present, no Miranda warnings). He admitted possessing drugs and firearms and then signed consent to a further search of the apartment, grounds, and detached garage.
- The subsequent search recovered four firearms, ~2.28 kg marijuana, ~95 g cocaine, and a white Kia Sorento found in a common garage (registered to Rodriguez) that matched surveillance of the fugitive’s vehicle.
- District court denied Segoviano’s motion to suppress; he pleaded guilty conditionally to reserve appeal of that denial. On appeal, Segoviano argued (1) statements/consent were involuntary because they were made during an unlawful detention, (2) detention was unlawfully extended beyond the sweep, and (3) he was subject to a Miranda‑less custodial interrogation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Lawfulness of detention/handcuffing and voluntariness of statements/consent | Segoviano: detention continued after sweep was unlawful and produced involuntary statements and consent | Government: agents had reasonable suspicion to detain under Terry (presence in building where fugitive might be; cellphone data; Rodriguez seen exiting; concern for officer safety) | Continued detention after the sweep violated the Fourth Amendment—agents lacked particularized reasonable suspicion as to Segoviano; statements/consent stemming from that detention tainted |
| Prolongation of detention beyond sweep | Segoviano: seizure was extended beyond its stated/justified purpose without new individualized suspicion | Government: prolongation was justified as reasonably related to the initial stop and by facts such as discovery of the Kia matching the fugitive’s vehicle | Prolongation unjustified; facts (cellphone ping near building, Rodriguez exiting, vehicle in common garage) did not provide individualized suspicion of harboring a fugitive and would apply to all residents |
| Miranda‑less custodial interrogation | Segoviano: statements required Miranda warnings because interrogation was custodial | Government: interrogation was investigatory/noncustodial (or justification not reached) | Appellate court did not resolve Miranda issue: suppressed evidence on Fourth Amendment grounds because the continued seizure was unlawful |
| Inevitable discovery (supplemental ruling) | Segoviano: evidence obtained via unlawful detention should be suppressed; inevitable discovery not applicable | Government: district court held firearms/drugs would have been found by warrant inevitably | Court held inevitable‑discovery ruling irrelevant to this appeal because the dispositive error was the unlawful seizure; appellate court reversed denial of suppression |
Key Cases Cited
- Steagald v. United States, 451 U.S. 204 (warrant needed to enter third‑party home to effect an arrest)
- Payton v. New York, 445 U.S. 573 (home threshold receives special Fourth Amendment protection)
- Caniglia v. Strom, 141 S. Ct. 1596 (home is core of Fourth Amendment privacy protections)
- Lange v. California, 141 S. Ct. 2011 (no categorical exception allowing pursuit into home without exigency)
- United States v. Cortez, 449 U.S. 411 (reasonable suspicion requires particularized, objective basis)
- Ybarra v. Illinois, 444 U.S. 85 (mere proximity to persons suspected of wrongdoing is insufficient)
- United States v. Ruiz, 785 F.3d 1134 (reasonable‑suspicion analysis relies on totality of circumstances)
- United States v. Ienco, 182 F.3d 517 (no reasonable suspicion where officers lacked articulable facts about the seized individual)
- United States v. Johnson, 170 F.3d 708 (propinquity to a place of suspected criminal activity does not justify seizure of an individual without more)
- United States v. Richmond, 924 F.3d 404 (discussion of Terry‑type stops in curtilage/home contexts)
Decision: Reversed the district court’s denial of the motion to suppress and remanded for further proceedings consistent with the opinion.