United States v. Shedrick D. Hollis, 780 F.3d 1064

Law enforcement had an outstanding Georgia arrest warrant for Shedrick Hollis and learned he was inside an apartment suspected to be a "drug house."
Officers surrounded the apartment, saw Hollis through a window, announced themselves, forced entry with a battering ram, and arrested him.
Officers conducted a protective sweep of the apartment incident to the arrest and observed marijuana on a dresser and kitchen counter and firearms under a bed in plain view.
After seizing the items in plain view, officers obtained a search warrant and discovered additional drugs, scales (one with a latent print later attributed to Hollis), and cash.
Hollis moved to suppress the evidence as the product of an illegal warrantless search; the district court denied the motion. At trial Hollis was convicted on all counts and sentenced to 420 months.

Issue	Hollis's Argument	Government's Argument	Held
Admissibility of evidence seized in third-party residence during arrest-related entry	Evidence should be suppressed because Hollis had a privacy interest as a guest and the searches were warrantless	Evidence was in plain view during a lawful protective sweep incident to a valid arrest; alternatively Hollis lacked a privacy interest	Court held evidence admissible: subject of arrest warrant cannot challenge seizure in third-party home when discovered in plain view during a valid protective sweep incident to arrest
Qualification and admissibility of fingerprint expert testimony	Yates should be allowed to testify about sufficiency of latent print for comparison	Court should exclude Yates because he is not qualified to perform fingerprint comparisons, and he testified sufficiency requires same expertise	Court refused Yates’s expert testimony on sufficiency; no abuse of discretion under Daubert

Payton v. New York, 445 U.S. 573 (1979) (arrest warrant generally authorizes entry into dwelling when there is reason to believe suspect is inside)
Maryland v. Buie, 494 U.S. 325 (1990) (protective sweep doctrine: limited search for persons posing danger during arrest in a residence)
Minnesota v. Dickerson, 508 U.S. 366 (1993) (contraband in plain view from lawful vantage point is not a Fourth Amendment search separate from the initial intrusion)
Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993) (district court’s gatekeeping role to assess admissibility and reliability of expert testimony)
United States v. Brown, 415 F.3d 1257 (11th Cir. 2005) (appellate deference to district court’s Daubert determinations)
United States v. Yeary, 740 F.3d 569 (11th Cir. 2014) (discussing plain-view discovery of contraband during a protective sweep)