United States v. Sturgis, 652 F.3d 842

Sturgis was convicted in 2004 of federal crack-cocaine distribution offenses, with evidence found in his car admitted over suppression objections.
On appeal, the Eighth Circuit affirmed but remanded twice for resentencing due to intervening Supreme Court decisions (Booker and later Kimbrough).
In 2011 the Supreme Court vacated the judgment and remanded for reconsideration of the car-search legality in light of Arizona v. Gant.
Police obtained a search warrant for 1526 Oliver Avenue North, and for a vehicle associated with occupants; officers found cash in Sturgis’s car and drugs in the residence.
Sturgis moved to suppress the car-evidence as violating the Fourth Amendment; the district court denied the motion and the appellate panel affirmed previously, before reconsideration post-Gant.
The central question is whether the warrant authorized the searches of Sturgis’s vehicle, given the warrant’s scope to occupants within and vehicles belonging to occupants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the car search within the warrant’s scope?	Sturgis argues occupants within did not include him since not inside when search started.	Sturgis’s position is that the warrant only covered occupants inside the house at search start.	Yes; the search was authorized.

United States v. Johnson, 640 F.3d 843 (8th Cir. 2011) (defines occupants to include those regularly staying at the address and with control; reads the warrant broadly)
Arizona v. Gant, 556 U.S. 332 (S. Ct. 2009) (limits automobile searches incident to arrest; prompted reconsideration of prior rationale)