United States v. Thomas Houck, 888 F.3d 957

Detectives traced child‑pornography sharing on a peer‑to‑peer network to an IP address at Houck’s mother’s residence, where they observed a pickup and a fifth‑wheel RV in the driveway.
Detective Kreider obtained a warrant to search the residence and expressly authorized searching “any vehicles . . . present at the time of execution.” He did not separately identify the RV.
At execution, the RV had Missouri plates, a VIN, inflated tires, was not permanently affixed, could be made roadworthy in ~30 minutes, but was connected to utilities and had a satellite dish.
Houck admitted owning a laptop with Ares software and said the laptop was in the RV; officers declined his offer to retrieve it and instead searched the RV under the warrant’s vehicle authorization.
Officers seized digital devices during the initial search and later obtained a second warrant specifically naming the RV after forensic preview indicated external storage devices; the second search recovered additional cameras.
The district court suppressed all evidence after finding the RV was being used as a residence and the vehicle authorization did not cover it; the government appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant’s authorization to search “any vehicles” included the RV	Houck: the RV was being used as a residence and thus fell outside the warrant’s vehicle scope	Government: RV is commonly a vehicle; warrant language reasonably covered the RV on the premises	Court: Officers’ belief that the RV was a vehicle was objectively reasonable; evidence not excluded
Whether officers’ mistaken belief (if any) requires suppression	Houck: mistake shows unreasonable search; suppression required	Government: at most an honest/reasonable mistake—exclusionary rule not warranted	Court: applied Garrison/Leon—reasonable mistake; exclusion not justified
Whether subsequent statements and evidence are fruits of an unlawful search	Houck: statements and later seizures flowed from illegal initial search	Government: initial search valid; even if not, officers acted reasonably	Court: because initial search was reasonable, subsequent evidence stands
Whether second warrant’s identification of the RV undermines officers’ original belief	Houck: specific second warrant shows RV was recognized as a residence and not a vehicle	Government: additional information developed after the initial search justified the second warrant	Court: second warrant does not prove bad faith; it reflected new information obtained during the initial lawful search

Maryland v. Garrison, 480 U.S. 79 (reasonableness of officers’ mistaken scope of warrant controls exclusion)
California v. Carney, 471 U.S. 386 (motor home may be treated as a vehicle under automobile‑exception analysis)
United States v. Leon, 468 U.S. 897 (exclusionary rule limited where officers act in objectively reasonable reliance)
Davis v. United States, 564 U.S. 229 (evidence obtained in reasonable reliance on binding precedent not excluded)
Herring v. United States, 555 U.S. 135 (suppression not required for negligent or reasonable law‑enforcement errors)
United States v. Patterson, 278 F.3d 315 (applying Garrison to uphold searches based on objectively reasonable beliefs)