United States v. Donnell Hopkins

Court of Appeals for the Eighth Circuit
824 F.3d 726 (2016)

ELI5:

Rule of Law:

Under the good faith exception to the exclusionary rule, evidence obtained from a search warrant will not be suppressed, even if the warrant was based on an unconstitutional search, so long as the officer's pre-warrant conduct was close enough to the line of legal validity that their subsequent reliance on the magistrate's warrant was objectively reasonable.

Facts:

Cedar Rapids police officer A1 Fear received information that a man known as 'Smoke' was dealing narcotics from the Cambridge Townhomes complex.
Officer Fear took his K-9, Marco, to the location to investigate.
Fear unhooked Marco from his leash and directed him to sniff along the exterior of the building where Donnell Hopkins rented a townhome.
Marco alerted to the odor of narcotics after sniffing within 6 to 8 inches of the bottom of the front door to Hopkins' unit, number 6.
After obtaining a warrant, Fear conducted surveillance and observed Hopkins engaging in what he believed to be narcotics transactions.
When officers arrived to execute the warrant, they found Hopkins standing outside his unit.
A search of Hopkins' person revealed a loaded handgun, crack cocaine, and marijuana.
A subsequent search inside Hopkins' townhome revealed a shoebox containing heroin, cocaine, and marijuana.

Procedural Posture:

Based on the dog sniff, Officer Fear applied for a search warrant, which an Iowa magistrate judge issued.
Hopkins was indicted in the United States District Court for the Northern District of Iowa for possession with intent to distribute controlled substances.
Hopkins filed a motion to suppress the evidence found on his person and in his townhome, arguing the dog sniff was an unconstitutional search.
A U.S. Magistrate Judge recommended denying the motion, concluding that while the sniff was unconstitutional, the Leon good faith exception applied.
The U.S. District Court adopted the magistrate's recommendation and denied Hopkins' motion to suppress.
Hopkins entered a conditional guilty plea, reserving his right to appeal the denial of his suppression motion.
Hopkins (appellant) appealed the district court's ruling to the U.S. Court of Appeals for the Eighth Circuit.

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Issue:

Does the good faith exception to the exclusionary rule permit the admission of evidence obtained from a search warrant that was based on an unconstitutional dog sniff of the curtilage immediately in front of a townhome's front door?

Opinions:

Majority - Murphy, Circuit Judge

Yes. The good faith exception permits the admission of the evidence because the officer's reliance on the search warrant was objectively reasonable. The court first determined that the dog sniff constituted an unconstitutional search under Florida v. Jardines. The area immediately in front of Hopkins' townhome door, where the dog sniffed, qualifies as curtilage under the four-factor Dunn test due to its close proximity to the home and its daily use by residents. Therefore, using a trained police dog to investigate this area was an unlicensed physical intrusion. However, the court held that the evidence was admissible under the good faith exception established in United States v. Leon. The officer's conduct was 'close enough to the line of validity' because at the time of the search, the application of Jardines (which involved a single-family house) to a multi-unit townhome was not clearly established. By disclosing all the relevant facts of the sniff to the magistrate, who then issued the warrant, the officer's reliance on that warrant was objectively reasonable, and the legal error rested with the magistrate, not the officer.

Analysis:

This decision reinforces the strength of the Leon good faith exception, particularly in cases where the underlying law is evolving or unsettled. It illustrates that a Fourth Amendment violation does not automatically trigger the exclusionary rule. By distinguishing the facts from prior cases and noting the lack of clear precedent on dog sniffs at multi-unit dwellings post-Jardines, the court provides a pathway for admitting evidence even when police conduct is later deemed unconstitutional. This creates a significant hurdle for defendants seeking suppression, requiring them to show not just that a search was illegal, but that a reasonably well-trained officer would have known it was illegal despite a magistrate's authorization.

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