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Narcotics Case Law Blog


Acute Behavioral Emergencies: What Every Officer Needs to Know in 2026
Law enforcement officers across the country are increasingly encountering individuals in severe behavioral crises. What was once commonly labeled “excited delirium” has evolved into a broader and more medically grounded understanding now referred to as Acute Behavioral Emergency (ABE) . The terminology has changed—but more importantly, so has the science, the legal landscape, and the expectations placed on officers. If your agency has not recently updated its policy or traini
Feb 135 min read


Stash House Search Warrant Lessons: Making the Firearm Charge Stick
United States v. Jones Citation: United States v. Jones, No. 24-4282, ___ F.4th ___ (4th Cir. Feb. 4, 2026) TL;DR The Fourth Circuit affirmed Lawrence Jones’s firearm convictions, holding that sufficient circumstantial evidence supported a finding of constructive possession of firearms discovered inside a drug stash house. Even without fingerprints, eyewitness testimony, or exclusive control of the premises, the totality of the evidence allowed the jury to reasonably conclud
Feb 114 min read


Furtive Movements Aren’t Magic Words: United States v. Erving and Protective Vehicle Searches
United States v. Erving Nos. 23-2828 & 23-2831 (7th Cir. Jan. 20, 2026) TL;DR The Seventh Circuit upheld a vehicle protective search under Michigan v. Long where a lone officer, late at night, observed furtive movements suggesting concealment, smelled burnt cannabis, learned the driver was on supervised release for a weapons offense, and reasonably believed the suspect could soon regain access to the vehicle. The court reaffirmed that reasonable suspicion—not probable cause
Feb 23 min read


Save a Life, Skip the Warrant: SCOTUS Backs Emergency Entry
Title & Citation Case v. Montana , 607 U.S. ___ (2026) (U.S. Supreme Court, Jan. 14, 2026). TL;DR Police can enter a home without a warrant to render emergency aid when they have an objectively reasonable basis to believe someone inside is seriously injured or imminently threatened with serious injury —and the Court refused to “upgrade” that standard into probable cause just because the entry is into a home. Here, the officers reasonably believed Case had shot himself or
Jan 164 min read


When Being Around a Gun Isn’t a Crime: The Limits of Constructive Possession in Louisiana
State v. Gerald Manchip White, 2024-K-01588 (La. Dec. 11, 2025) Holding: The Louisiana Supreme Court reversed all convictions against a felon accused of possessing firearms found in a family home. The State failed to prove he exercised dominion and control over the guns or had the intent to possess them. Mere presence, awareness, or living in a home where others lawfully keep guns is not enough for a criminal conviction. Importance: Officers frequently encounter multi-occ
Dec 12, 20255 min read


When Suspicion Isn’t Enough — and When It Is: A Training Comparison of State v. Matt (Montana) and Moody v. State (Mississippi)
Police officers routinely face one of the hardest judgment calls in criminal enforcement: Does what I’m seeing amount to mere suspicion, or does it rise to probable cause or proof of possession? Two recent appellate decisions — State v. Matt (Montana 2025) and Moody v. State (Mississippi 2025) — offer a powerful, real-world contrast that every patrol officer, interdiction unit, and investigator can learn from. One conviction was reversed because the evidence never crossed
Nov 30, 20254 min read


When “Trusted” Informants Sink a Warrant: What United States v. Felton Teaches Officers About Affidavits, Omissions, and GPS Trackers
In law enforcement, we rely heavily on confidential informants. Many times, they’re the difference between having a good hunch and having actual probable cause. But the Seventh Circuit’s decision in United States v. Felton (2025) gives us an important reminder: if your warrant affidavit leans on an informant, you must tell the judge the whole story — not just the parts that help you. This case walks through what happens when officers omit key credibility details , fail to co
Nov 30, 20254 min read


When Reliable Isn’t Enough: Why Nagle Was Suppressed and Long Wasn’t
Cases Compared: State v. Nagle , No. A23-0927 (Minn. Oct. 22, 2025) United States v. Long , No. 24-3377 (6th Cir. Oct. 17, 2025) TL;DR Holding (Nagle): Minnesota’s high court suppressed evidence from a home search based solely on an uncorroborated informant tip. Holding (Long): The Sixth Circuit upheld a home search based on a pattern of corroborated surveillance and drug activity. Importance: These two cases, decided just days apart, show the razor-thin line between pro
Nov 4, 20253 min read
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