This episode of Short Circuit covers Fourth Amendment cases where evidence of illegal firearms possession is suppressed. The Tenth Circuit rules a discovery of an M-16 in a tow truck violates the Fourth Amendment, just like the Eighth Circuit ruling on a warrant to search a shady character's home. The host also mentions a Christmas special and introduces upcoming guests.
The Tenth Circuit suppresses evidence of an illegal firearm found in a tow truck during an inventory search, highlighting the importance of balancing public safety concerns and Fourth Amendment rights.
The Eighth Circuit affirms the suppression of evidence found during a search warrant that lacked probable cause, emphasizing the need to distinguish between property and a residence when evaluating search warrant applications.
Deep dives
Case Summary: United States vs. Ramos
In this Fourth Amendment case heard in the 10th Circuit, a police officer in a small town in Oklahoma arrests a former classmate for slapping him lightly on the cheek. The officer subsequently decides to impound the defendant's tow truck, which was parked in a convenience store lot. During an inventory search of the truck, the officer finds an M16 machine gun. The defendant argues that the impoundment violated the Fourth Amendment and files a motion to suppress the evidence. The district court denies the motion, but the 10th Circuit determines that the officer did not meet the standard of legitimate caretaking rationale outlined in their five-factor test. The court emphasizes the importance of balancing public safety concerns and an individual's Fourth Amendment rights.
Case Summary: Ralston vs. United States
In this case from the 8th Circuit, law enforcement officers obtain a search warrant for a property where the defendant, Ralston, resides. The warrant is based on suspicions that a person known for stealing property is frequenting a mobile home on the property. During the search, no stolen property is found, but a firearm is discovered, leading to Ralston being charged with illegal possession of a firearm. The district court grants Ralston's motion to suppress the evidence, concluding that the warrant was overbroad and lacked probable cause. The 8th Circuit affirms the decision, emphasizing that mere suspicions and a person's reputation are not sufficient to establish probable cause for a search. The court highlights the importance of distinguishing between property and a residence when evaluating search warrant applications.
Rare Ruling: Judge Overrules Magistrate in Search Warrant Case
A noteworthy aspect of the Ralston case is the district court's decision to overrule the recommendation of the magistrate who initially approved the search warrant. This is a rarity and signals to the appellate court the need for a closer look. The court highlights the significance of the good faith exception in search warrants and emphasizes that this exception does not apply in this case. The evidence is suppressed because the search warrant was deemed overbroad and lacked probable cause. The rarity of this outcome underscores the importance of ensuring that search warrants meet the legal standard and uphold individuals' Fourth Amendment rights.
Understanding Motions to Suppress and Their Impact
Motions to suppress evidence, like those seen in both cases discussed, are often pivotal in protecting an individual's Fourth Amendment rights against unreasonable searches and seizures. However, data on the percentage of granted motions to suppress remains limited due to various factors such as underreporting and strategic considerations by defense attorneys. Studies suggest that about one-third of filed motions to suppress are granted, but this statistic does not account for instances where individuals choose to forgo filing a motion. The scarce data and lack of a comprehensive tracking system highlight the need for a robust feedback loop to enhance accountability and enable accurate assessment of the Fourth Amendment's application in practice.
Motions to suppress evidence of illegal firearms possession seem to be all the rage these days, or at least on this episode. IJ’s Christie Hebert starts things off in the Tenth Circuit where an altercation between former high school classmates (one of whom is a cop) leads to the discovery of an M-16 in the back of a tow truck. Was that a Fourth Amendment violation or a permissible inventory search? The court thinks the former and suppresses the evidence. The same is true in the Eighth Circuit, where IJ’s Evan Lisull tells us the police can’t get a warrant to search someone’s home just because the guy who lives there is a shady character. Evan also explains what it’s like to live on a nine-acre lot in rural Iowa and how “city mice” might not understand.
