United States v. Prentiss Anthony Crumble, 878 F.3d 656

On Oct. 21, 2014 police responded to shots fired between vehicles; a tan Buick crashed into a house and its two male occupants fled on foot. A handgun was observed in the Buick and a cell phone was found on the driver’s seat.
Witnesses described one fleeing occupant as a Black male in a white T‑shirt; officers found Prentiss Crumble hiding nearby and brought him to the crash scene; he initially denied knowledge of the Buick.
Police seized the cell phone and obtained a warrant the next day to search its electronic data; the search produced a video of Crumble in a white T‑shirt brandishing a handgun recorded minutes before the shooting.
Crumble was charged under 18 U.S.C. §§ 922(g)(1) and 924(e) (ACCA). He moved to suppress the phone evidence; the magistrate recommended suppression but the district court denied the motion, finding abandonment (and alternatively that the warrant was valid or relied upon in good faith).
Crumble pleaded guilty conditionally to preserve the suppression issue and was sentenced under the ACCA based on prior Minnesota convictions (one second‑degree assault, one second‑degree burglary, two third‑degree burglaries).
On appeal the Eighth Circuit affirmed denial of suppression (abandonment) but held Minnesota second‑ and third‑degree burglary convictions are broader than generic burglary and do not qualify as ACCA violent‑felony predicates; the ACCA sentence was vacated and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Crumble had a reasonable expectation of privacy in the cell phone found in the Buick (Fourth Amendment)	Crumble: cell phones are uniquely private (Riley) and he did not abandon the phone because he fled from a shooter, not to abandon possessions.	Govt: Crumble abandoned the Buick and its contents by fleeing, leaving key, open/shot window, gun visible, and by denying ownership; abandonment is judged by objective facts.	Court: Affirmed district court — objective facts support abandonment; search implicates no Fourth Amendment protection, so suppression denied.
Whether Minnesota second‑ and third‑degree burglary convictions qualify as ACCA "violent felonies" (predicate offenses)	Crumble: Minnesota burglary convictions are broader than generic burglary and therefore do not qualify.	Govt: Initially urged ACCA application but conceded burglaries did not qualify.	Court: Applied McArthur/categorical approach — Minnesota second‑ and third‑degree burglary include an overbroad alternative (commission of a crime after entry) and are not ACCA violent felonies; ACCA sentence vacated.

Riley v. California, 134 S. Ct. 2473 (2014) (cell phones contain extensive private data; search‑incident‑to‑arrest exception does not justify warrantless phone searches)
Taylor v. United States, 495 U.S. 575 (1990) (defines "generic" burglary for ACCA purposes)
Descamps v. United States, 133 S. Ct. 2276 (2013) (categorical and modified categorical approaches to determining whether prior convictions qualify as predicates)
United States v. McArthur, 850 F.3d 925 (8th Cir. 2017) (Minnesota third‑degree burglary is indivisible and broader than generic burglary)
United States v. Tugwell, 125 F.3d 600 (8th Cir. 1997) (abandonment doctrine: warrantless search of abandoned property does not implicate Fourth Amendment)