United States v. Tyslen Baker, 976 F.3d 636

Officer Render checked Kentucky’s e-warrant system, found an active arrest warrant for Tyslen Baker for receiving stolen property at 302 N. Kentucky, Madisonville.
Render and Officer Knelson approached the hybrid store/residence; a man (Baker) voluntarily opened the front door and let them into the store area.
Render asked for identification; Baker moved quickly through an interior door toward a back room to retrieve his ID, and Render followed to maintain visual control during the arrest.
In the back room Render observed a rifle and jars of marijuana in plain view; Baker, a felon, was handcuffed; a pocket search and later search warrant uncovered cocaine, methamphetamine, marijuana, and firearms.
Baker moved to suppress, arguing (1) Render’s entry into the back room was an unlawful seizure and (2) the affidavit supporting the arrest warrant lacked probable cause; the district court denied suppression. The Sixth Circuit affirmed.

Issue	Plaintiff's Argument (Baker)	Defendant's Argument (Government)	Held
Lawfulness of officer's entry/movements while executing arrest warrant	Render unlawfully entered/back room without consent and effected an unreasonable seizure	Render obtained entry to store by consent, reasonably followed Baker to monitor movements during arrest (safety), plain-view justified seizure	Entry and monitoring were reasonable under Fourth Amendment (consent/knock-and-talk; Chrisman/Buie principles); evidence in plain view admissible
Probable cause for arrest warrant and applicability of exclusionary rule	Affidavit (from Officer King) was bare-bones: unreliable informant, insufficient nexus/recency to show Baker knowingly received stolen property; suppression required	Affidavit contained a modicum of evidence linking Baker (informant said Baker sold the pawned tablet); officers reasonably relied on judicial probable-cause finding; Leon/Herring good-faith exception applies to arrest warrants	Court declined to decide deficiency of probable cause; held affidavit not bare-bones so Leon’s good-faith exception bars suppression (Leon framework can apply to arrest warrants)

Washington v. Chrisman, 455 U.S. 1 (1982) (officer may monitor arrestee’s movements and observations in plain view during arrest)
United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to exclusionary rule for warrants issued by magistrate)
Herring v. United States, 555 U.S. 135 (2009) (exclusionary rule unnecessary where error was negligent and not deliberate)
Payton v. New York, 445 U.S. 573 (1980) (need for arrest warrant to enter home absent consent or exigency)
United States v. Watson, 423 U.S. 411 (1976) (warrantless public arrests reasonable with probable cause)
Maryland v. Buie, 494 U.S. 325 (1990) (protective sweeps of areas immediately adjoining place of arrest permissible without probable cause)
Hiibel v. Sixth Judicial Dist. Ct. of Nev., 542 U.S. 177 (2004) (requesting identification does not necessarily constitute a seizure)
United States v. Hensley, 469 U.S. 221 (1985) (officers may rely on information from other jurisdictions and need not re-prove probable cause)
Horton v. California, 496 U.S. 128 (1990) (plain-view doctrine; illegality immediately apparent may justify seizure)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (probable cause is a practical, non-technical standard)
United States v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause and deference to magistrate)
Arizona v. Evans, 514 U.S. 1 (1995) (reasonable reliance on official records can excuse Fourth Amendment violation)