835 F.3d 13
1st Cir.2016Background
- Police obtained an arrest warrant for Lamar Young (charged in a drug conspiracy) and conducted nighttime checks of multiple addresses where Young had stayed or been located previously.
- An informant (Webster) told officers that if Young was not at three known addresses he "had to be back" with his former girlfriend, Jennifer Coleman, and described Coleman’s building.
- Six officers went to Coleman’s Walnut Street apartment at about 11:00 p.m.; two officers entered through a rear door, knocked, and one officer stepped inside without Coleman’s consent as Coleman’s daughter opened the door.
- Officers proceeded down a narrow hallway, found Young kneeling on Coleman’s bed, arrested him, and—during an hour-long post-entry interrogation (mostly later suppressed as Miranda violations)—Young disclosed locations of drugs and a firearm, which were seized; Coleman later consented to searches after Young was removed.
- The district court denied Young’s motion to suppress the seized evidence (while suppressing most of his statements), concluding officers had a reasonable belief Young lived at and was present in Coleman’s apartment; Young appealed.
- The First Circuit majority held pre-entry information was insufficient to establish a reasonable belief Young resided at and was present in Coleman’s apartment, so the warrantless entry violated the Fourth Amendment; the conviction was vacated and suppression ruling reversed.
Issues
| Issue | Plaintiff's Argument (Gov't) | Defendant's Argument (Young) | Held |
|---|---|---|---|
| Whether officers reasonably believed Young resided at Coleman’s apartment (Payton residence inquiry) | Webster’s tip plus officers’ knowledge of prior Coleman–Young relationship and recognition of Coleman’s car made belief reasonable | Tip was speculative, dated; officers had no contemporary proof Young lived with Coleman | Held for Young: pre-entry facts insufficient to support reasonable belief of residence |
| Whether officers reasonably believed Young was present when they entered (Payton presence inquiry) | Time of night, eliminated other addresses, and contemporaneous circumstances made presence plausible | Time-of-day alone and lack of verification (surveillance, calls) insufficient to infer presence | Held for Young: no reasonable belief Young was present pre-entry |
| Whether post-entry observations (Coleman’s confirmation, Michaud’s sighting at window) can validate entry retroactively | Government relied on some post-entry observations to ‘‘strengthen’’ belief | Post-entry information cannot justify the initial threshold crossing under Payton | Held for Young: court rejects reliance on post-entry info to justify entry |
| Whether any exception (consent, exigency, inevitable discovery) saves admission of seized evidence | Government suggested implied/after-the-fact consent and alluded to inevitable discovery theories | Entry was unlawful and subsequent statements largely Miranda-tainted; government failed to carry inevitable discovery or lawful-entry arguments below | Held for Young: evidence discovered after unlawful entry must be suppressed; government failed to show lawful exception on this record |
Key Cases Cited
- Payton v. New York, 445 U.S. 573 (1980) (officers executing an arrest warrant may enter a residence without a search warrant only if they reasonably believe the suspect lives there and is present)
- Werra v. United States, 638 F.3d 326 (1st Cir. 2011) (Payton framework and limits on using post-entry discoveries to justify entry)
- Graham, 553 F.3d 6 (1st Cir. 2009) (totality-of-the-circumstances review of officers’ reasonable belief under Payton)
- Hamilton v. United States, 819 F.3d 503 (1st Cir. 2016) (articulating two-part Payton residency and presence inquiry)
- Miranda v. Arizona, 384 U.S. 436 (1966) (custodial-interrogation warnings requirement)
- Solis-Alarcon v. United States, 662 F.3d 577 (1st Cir. 2011) (officers cannot search a third party’s home on an arrest warrant absent exigency or consent)
- Utah v. Strieff, 136 S. Ct. 2056 (2016) (discussing inevitable discovery and limits of exclusionary rule remedies)
- United States v. Bohannon, 824 F.3d 242 (2d Cir. 2016) (alternative framing: entry lawful where officers had an arrest warrant and reason to believe suspect was inside)