United States v. Andino

Defendant was indicted for possession charges after officers conducted a warrantless entry into her home and seized cocaine. On appeal, the Government challenged the district court's grant of defendant's motion to suppress the cocaine. The officers reasonably believed that defendant was destroying evidence by washing cocaine down the kitchen sink. The objective of the warrantless entry was to stop the destruction of evidence, and the officers' entry into the kitchen was limited to achieving that objective. Simply securing defendant did not accomplish this purpose. The court agreed with the district court that exigent circumstances justified the warrantless entry into defendant's home. The court concluded, however, that the district court erred in determining that exigent circumstances did not also justify the officers' warrantless entry into the kitchen where the cocaine was found. Accordingly, the court reversed that portion of the order and remanded. View "United States v. Andino" on Justia Law