United States v. Wright, 5:19-cr-00016

On January 15, 2019, William Ames called 911 reporting a strong-arm robbery; he described the suspect (Wright) and a blue Ford pickup.
Deputies and Air 1 located a matching truck at Wright’s rural mobile-home property; the truck’s engine was warm, and thermal imaging confirmed recent use.
Air 1 observed an individual fleeing from the rear of the residence and hiding behind a travel trailer; Deputy Gray entered the yard (over a partially down fence), announced, and detained Wright as he emerged with hands up.
Wright was wearing a Rolex and necklace reported stolen; he denied the robbery in a post‑Miranda interview, claimed the items were his, and refused consent to search.
A search warrant obtained and executed the next day recovered multiple firearms and ammunition (including loaded handguns in the freezer and bedroom) and a stolen Porsche with weapons; Wright later admitted handling some of the recovered guns.
Wright moved to suppress evidence seized after the warrantless entry and to suppress evidence obtained via the subsequent warrant/complaint as fruit of the poisonous tree; the magistrate recommended denial, finding exigent circumstances justified the entry and the later evidence was not tainted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of the warrantless entry onto the property/curtilage	Exigent circumstances justified entry: suspect of violent felony was fleeing, risk of evidence destruction, and officer safety concerns	Entry violated Fourth Amendment protections for the home/curtilage and required a warrant	Entry was justified by exigent circumstances; warrantless entry lawful and detention valid
Whether subsequent search warrant and federal complaint were tainted by the warrantless entry	The subsequent warrant and complaint were not tainted; evidence was lawfully obtained following a proper warrant	Subsequent evidence was fruit of the poisonous tree because it flowed from an unlawful entry	Subsequent warrant and complaint were not tainted; evidence admissible

Florida v. Jardines, 569 U.S. 1 (2013) (curtilage is part of the home for Fourth Amendment purposes)
Oliver v. United States, 466 U.S. 170 (1984) (discussing curtilage and expectations of privacy)
Payton v. New York, 445 U.S. 573 (1980) (warrantless entry into a home is presumptively unreasonable)
United States v. Holloway, 290 F.3d 1331 (11th Cir. 2002) (government bears burden to show an exception to the warrant requirement; exigent-circumstances framework)
Johnson v. United States, 333 U.S. 10 (1948) (hot pursuit/flight can justify warrantless action)