Narcotics Case Law Blog

United States v. Evans, No. 24-2156 (3d Cir. May 19, 2026) TL;DR The Third Circuit affirmed the convictions of a New Jersey man after police found guns, fentanyl, methamphetamine, heroin, cocaine, marijuana, packaging materials, and cash inside his hotel room. Officers discovered additional drugs hidden above ceiling tiles during the execution of a search warrant. The Court held: Officers acted reasonably when they searched the hotel room ceiling after noticing signs that con

Bolton v. Sheriff of Coweta County, Georgia, No. 23-12752 (11th Cir. May 21, 2026) TL;DR The Eleventh Circuit ruled that Georgia deputies did not use excessive force when one deputy shot a suspect who continued accelerating his SUV after a pursuit and collision with patrol cars. The court held the deputies were entitled to qualified immunity because the suspect’s vehicle still posed an immediate threat, even while partially boxed in. The court also found that the force used t

Fuhr v. City of Seattle, No. 24-5618 (9th Cir. May 7, 2026) TL;DR The Ninth Circuit held that a Seattle SWAT officer who shot and killed a fleeing suspect holding an infant child was entitled to qualified immunity because no clearly established law prohibited the officer’s actions under the specific facts of the case. The court emphasized that the suspect had previously fired a gun in a public park, ignored repeated commands, fled from police for more than thirty minutes whil

United States v. Allen Citation: No. 24-4604 (4th Cir. Apr. 28, 2026) Court: U.S. Court of Appeals for the Fourth Circuit Decision Date: April 28, 2026 TL;DR Holding: Evidence found in Allen’s bags was admissible under the inevitable discovery doctrine because it would have been uncovered during mandatory inventory searches at booking. Why it matters: Even if a search incident to arrest is invalid, evidence can still come in if standardized inventory policies would have uncov

Ruffin v. Davis (4th Cir. 2026) Docket Number: 25-1318, April 29, 2026 TL;DR Holding: The Fourth Circuit held that an officer is not entitled to qualified immunity when he uses deadly force on a fleeing suspect—even an armed one—who does not make a threatening or furtive movement with the weapon. Why it matters: This is a major reaffirmation (and tightening) of Tennessee v. Garner + Graham v. Connor: Being armed + running + ignoring commands still does NOT justify deadly forc

Byers v. Painter (4th Cir. 2026) Citation: No. 25-1058 (4th Cir. Apr. 17, 2026) TL;DR Holding: Officer not entitled to qualified immunity at motion-to-dismiss stage for fatal shooting of armed but non-threatening suspect. Why it matters: Reinforces that possession of a weapon + noncompliance ≠ automatic deadly force—there must be a real, immediate threat. Key limit: Case is at the pleading stage—facts are viewed in plaintiff’s favor, and video must clearly contradict them to

District of Columbia v. R.W. (2026) Citation: 608 U.S. ____ (2026) TL;DR Holding: Officers had reasonable suspicion to stop a driver where (1) a dispatch reported a suspicious vehicle, (2) passengers fled upon police arrival, and (3) the driver immediately attempted to leave with a door still open. Why it matters: The Supreme Court reinforces that courts must evaluate reasonable suspicion using the totality of the circumstances—not by isolating and discarding individual facts

Alexander v. Arceneaux , No. 25-30016 (5th Cir. Apr. 13, 2026) TL;DR Holding: Officers did not violate the Fourth Amendment when they seized electronics and appliances not listed in a firearm warrant because the items were lawfully seized under the plain view doctrine . Why it matters: This case reinforces that plain view is driven by probable cause—not certainty . Officers can seize unlisted items if the totality of circumstances makes it reasonably apparent they are cont