United States v. Joseph White, 748 F.3d 507

White arrested approximately 20 feet outside his home; dispatch described a potential domestic disturbance with a firearm and possible barricading
Troopers arrived at a trailer home, observed White and his daughter, and detained them with weapons drawn
Trooper Hoban conducted a cursory search of the mud room and seized a revolver and a shotgun found just inside the threshold
Samantha White remained outside; troopers conducted a room-by-room walkthrough and found no other persons but observed gun cases and a burnt marijuana cigarette
May 4, 2012: authorities obtained a search warrant based in part on the two seized firearms and seized 91 additional firearms during the residence search
White pled guilty to felon in possession, reserving the right to appeal the suppression ruling; appeal challenges only the suppression order

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Buie prong 1 applies to the arrest outside the home	White authority relies on prong 2 for outside-home arrests; prong 1 should not apply	Government contends prong 1 permits a limited sweep as incident to arrest	Buie prong 1 not applicable; arrest outside the home requires prong 2 analysis
Whether the search of the home was permissible under Buie and related exceptions	Search was not justified by prong 1 or 2; no exigent circumstances shown	Government relies on Buie prong 1 or exigent circumstances to justify the sweep	Remand needed to consider prong 2 and exigent-circumstances exceptions; not decided on appeal
Whether a remand is appropriate to develop other suppression defenses	Record insufficient to assess prong 2 or exigent circumstances	Lower court record adequate for review on appeal	Remand to district court for further proceedings consistent with Buie and related standards

Buie, 494 U.S. 325 (1990) (protective sweep incident to arrest; prongs 1 and 2)
Sharrar v. Felsing, 128 F.3d 810 (3d Cir. 1997) (outside-the-home arrest sweep analyzed under prong 2)
Payton v. New York, 445 U.S. 573 (1980) (home entry Fourth Amendment protections)
Jardines, 133 S. Ct. 1409 (2013) (homeinuco Fourth Amendment line at entrance; search considerations)
Kyllo v. United States, 533 U.S. 27 (2001) (bright-line home-entry protection)
Maryland v. Buie, 494 U.S. 333 (1990) (Buie framework for sweeps; prong distinctions)
Illinois v. Wardlow, 528 U.S. 119 (2000) (reasonable suspicion standard)
Kentucky v. King, 131 S. Ct. 1849 (2011) (exigent circumstances exception to warrant requirement)
United States v. Coles, 437 F.3d 361 (3d Cir. 2006) (exigent-circumstances and scope considerations)
United States v. Latz, 162 F. App’x 113 (2005) (non-precedential; distinguishable arrest location)