United States v. Bohannon, No. 14-4679 (2d Cir. 2016)
Annotate this CaseOn this interlocutory appeal, the United States challenges the district court's order suppressing drugs and money seized incident to defendant's arrest in the home of Shonsai Dickson. The court concluded that, whether the subject of an arrest warrant is apprehended in his own home or a third‐party residence where he is a guest, his Fourth Amendment privacy rights with respect to entry of either premises are those stated in Payton v. New York, at the time of entry, arresting officers must possess (a) a valid arrest warrant for the subject and (b) reason to believe that the subject is then in the premises. The third‐party resident’s Fourth Amendment right in such circumstances to have the entry into his home authorized by a search warrant, does not extend to the subject of the arrest warrant. The court also concluded that the totality of circumstances known to law enforcement authorities at the time they entered third party Dickson’s residence to execute a valid warrant for defendant’s arrest supported reason to believe that defendant was then in those premises. Accordingly, the court vacated the suppression order to the extent it concluded that the entry of Dickson’s apartment violated defendant’s Fourth Amendment rights, and remanded.
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