United States v. Stokes
2013 WL 4417572
2d Cir.2013Background
- Stokes was convicted after a bench trial on stipulated facts of felon in possession (18 U.S.C. § 922(g)(1)) and possession of a machine gun (18 U.S.C. § 922(o)(1)).
- Officers entered Stokes’s motel room without a warrant or consent, relying on the inevitable discovery doctrine to justify the evidence obtained.
- District court denied suppression, concluding the firearms would inevitably have been discovered absent the illegal entry.
- Stokes and a companion were staying at Pelham Garden Motel; officers entered after attempting (but not obtaining) an arrest warrant.
- Patel, the motel manager, testified the staff would turn over contraband found in ordinary course of business; a later affidavit described such practices.
- This appeal centers on whether inevitable discovery can justify admitting the seized firearms despite unlawful entry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether inevitable discovery supports admitting the firearms | Government urged inevitable discovery would occur | Stokes contends contingencies were not proven | Inevitable discovery not proven; suppression affirmed (vacated/reversed) |
Key Cases Cited
- United States v. Cabassa, 62 F.3d 470 (2d Cir. 1995) (inevitable discovery requires high confidence all contingencies favor government)
- Heath v. United States, 455 F.3d 52 (2d Cir. 2006) (inevitable discovery requires demonstrated historical facts with favorable contingencies)
- Nix v. Williams, 467 U.S. 431 () (burden on government to prove inevitable discovery by preponderance of evidence)
- United States v. Eng, 971 F.2d 854 (2d Cir. 1992) (emphasizes focus on verified historical facts for inevitability analysis)