United States v. Pimentel, 26 F.4th 86

Police obtained a no‑knock warrant for "88 Fountain St. 2nd floor" after shots were fired and evidence pointed to Kadeem Pimentel as the shooter and possessor of a sawed‑off shotgun.
The warrant application and a handwritten clarification identified Pimentel as a second‑floor resident based on HPD records, but Pimentel had recently moved to the third floor of the three‑unit, family‑occupied building.
Officers executed the warrant at ~2:30 a.m.; during the sweep they encountered Pimentel coming down the back stairs from the third floor and were told his girlfriend and aunt were upstairs.
After Miranda warnings, Pimentel admitted two shotguns were in his bedroom (understood to be on the third floor); officers then searched the third‑floor bedroom and seized two shotguns and related items.
Pimentel (a felon) was indicted under 18 U.S.C. § 922(g)(1), moved to suppress the third‑floor evidence as beyond the warrant’s scope, the district court denied suppression under the Leon good‑faith exception, he pleaded guilty and appealed.
The First Circuit affirmed, holding the warrant’s text and on‑scene facts rendered the officers’ belief that the third floor was covered objectively reasonable, so Leon applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search of the third‑floor apartment exceeded the warrant’s scope and requires suppression	U.S.: Warrant read in context was ambiguous and focused on Pimentel personally; officers reasonably believed it covered his residence where the guns were found	Pimentel: Warrant specifically authorized only the 2nd‑floor unit; searching the 3rd floor violated the Fourth Amendment and Leon does not save the fruits of that search	Court: Warrant ambiguous in light of the affidavit and on‑scene facts; officers’ belief was objectively reasonable and Leon’s good‑faith exception applies, so suppression denied

United States v. Leon, 468 U.S. 897 (U.S. 1984) (establishes the objective good‑faith exception to the exclusionary rule)
Maryland v. Garrison, 480 U.S. 79 (U.S. 1987) (applies good faith when a unit was mistakenly included in a warrant but officers acted reasonably upon discovery)
United States v. Woodbury, 511 F.3d 93 (1st Cir. 2007) (affirmed Leon where wrong unit was listed but officers targeted the defendant’s actual unit in good faith)
United States v. Fuccillo, 808 F.2d 173 (1st Cir. 1986) (distinguishes cases where officers clearly exceed an unambiguous warrant and good faith fails)
Rawlings v. Kentucky, 448 U.S. 98 (U.S. 1980) (officer errors about scope not necessarily grave enough to require exclusion)
Davis v. United States, 564 U.S. 229 (U.S. 2011) (Leon applies across a range of cases, including police errors)
Herring v. United States, 555 U.S. 135 (U.S. 2009) (good‑faith exception can apply to negligent police mistakes)