United States v. Shaun Farrington, 42 F.4th 895

In Oct. 2019 police surveilled a motel, observed Farrington and Stefani Goodwin place several bags into a car, and stopped the vehicle because Farrington’s license was suspended.
A drug-detection dog alerted; officers found paraphernalia and four locked lockboxes in the car, arrested Farrington, seized the lockboxes, and moved them to the sheriff’s evidence shed.
That evening a drug dog sniffed the lockboxes at the shed and alerted; officers obtained a search warrant roughly two hours later and searched the lockboxes, discovering methamphetamine.
Farrington moved to suppress evidence from the stop, seizure, and sniff; the district court denied suppression.
At trial the court admitted a 12-second jail-video excerpt of Farrington’s call but excluded about 1.5 minutes of additional footage under Rule 106; a juror who previously corresponded with a Government witness was challenged for cause and not struck.
Farrington was convicted of possession with intent to distribute and conspiracy; he appealed the denials on suppression, juror challenge, and Rule 106 exclusion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Suppression: Were seizure, hours-long detention, and dog sniff of lockboxes unlawful under the Fourth Amendment?	Farrington: detention and second dog sniff/search of lockboxes was an unreasonable seizure/search (invoking Place).	Government: automobile exception permits seizure/search of containers; Johns allows delayed searches; dog sniff on exterior not a search.	Affirmed. Johns controls; delay was reasonable and warrant obtained; suppression properly denied.
Juror challenge: Should a juror who previously corresponded with a Rule 404(b) witness be struck for cause?	Farrington: prior frequent email contact with Detective Bunch created implied or actual bias requiring removal.	Government: juror explicitly said she could be fair and would wait to hear testimony; no actual partiality shown.	Affirmed. Denial not an abuse of discretion; juror professed impartiality and any misapplied standard was harmless.
Rule 106: Should additional portion of jail-call be admitted to provide context?	Farrington: 12‑second excerpt created misleading impression; longer portion would explain "lawyer" and "lockboxes" remarks.	Government: additional footage would only reinforce Government’s characterization; district court reviewed full video and found no contextualizing material necessary.	Affirmed. Exclusion was not an abuse of discretion because Farrington failed to show the additional portion was necessary to avoid misleading the jury.

United States v. Johns, 469 U.S. 478 (upheld delayed warrantless search of containers removed from vehicles)
California v. Acevedo, 500 U.S. 565 (automobile-exception principles for containers in vehicles)
United States v. Place, 462 U.S. 696 (distinguished as inapplicable to automobile-exception context)
United States v. Aungie, 4 F.4th 638 (party invoking Rule 106 must specify how omitted material distorts admitted portion)
McCoy v. Augusta Fiberglass Coatings, Inc., 593 F.3d 737 (Rule 106 burdens and limits)
United States v. Ramos-Caraballo, 375 F.3d 797 (standard of review for Rule 106 rulings)
Moran v. Clarke, 443 F.3d 646 (abuse-of-discretion review for juror-strike denials)
United States v. Tibesar, 894 F.2d 317 (requirement to show actual partiality to strike juror for cause)