United States v. Rodriguez-Pacheco, 948 F.3d 1

Rodríguez, a Puerto Rico police officer, was accused of domestic violence; officers went to his mother's home to seize his service weapon and arrest him under department procedure.
When Rodríguez came outside and said the gun was in his bedroom, Officer Murillo followed him inside (Rodríguez later denied consenting to entry). Officers seized the service weapon, a laptop, a GoPro, and a cellphone.
A warrant was later obtained to search the electronics; the search revealed evidence of sexual abuse of the complainant and images/videos of minors, leading to federal child-pornography indictments.
Rodríguez moved to suppress the seized electronics and statements; the magistrate judge and district court found probable cause and upheld the warrantless entry under exigent circumstances, denying suppression of the seized evidence.
On appeal the First Circuit held the record does not support exigent circumstances sufficient to justify the warrantless entry and remanded for the district court to make findings on consent, which the lower court had not resolved.

Issue	Rodríguez's Argument	Government's Argument	Held
Whether officers lawfully entered home without a warrant under exigent- circumstances	Entry unconstitutional: no evidence of emergency, no violence, Rodríguez unarmed and cooperative; mere presence of gun insufficient	Entry justified: department protocol required immediate arrest and seizure of service weapon; reasonable officers would not let suspect fetch weapon	Exigent-circumstances justification rejected: record lacks urgency, threat, or other factors that our precedents require
Whether officers had consent to enter	Denies consenting to entry	Government originally asserted consent as sole justification (but lower courts relied on exigency instead)	No factual finding on consent below; remanded for district court to resolve credibility and consent findings
Whether seizure of electronics and evidence was admissible as plain view/derivative of entry	Seizure flowed from unconstitutional entry; evidence should be suppressed	Entry and seizure justified (exigency or consent); search warrant later obtained for electronics	Because entry was unconstitutional on this record, seizure cannot be upheld on exigency; suppression issue contingent on consent findings on remand
Scope of remedy/proceeding	Suppress evidence and statements obtained from unconstitutional entry	Maintain convictions; defend search warrant and evidence	Case remanded for district court factfinding on consent; appellate court retains jurisdiction

Payton v. New York, 445 U.S. 573 (warrantless entry into home presumptively unreasonable)
Georgia v. Randolph, 547 U.S. 103 (limits on third-party consent to enter)
Kentucky v. King, 563 U.S. 452 (exigent- circumstances framework and split-second judgments)
United States v. Lopez, 989 F.2d 24 (search for weapon upheld where firearm recently used to threaten victim)
United States v. Samboy, 433 F.3d 154 (exigent-circumstances standard and burden on government)
United States v. Almonte-Báez, 857 F.3d 27 (exigent circumstances can justify warrantless apartment entry in appropriate facts)
United States v. Irizarry, 673 F.2d 554 (no exigency where no compelling need for immediate action)
Bilida v. McCleod, 211 F.3d 166 (examples of exigent circumstances and application)