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Case Law Blog


Phone First, Warrant Second? The Eighth Circuit Upholds Emergency Seizure of Digital Evidence
United States v. Evans, No. 25-1926 (8th Cir. June 9, 2026) TL;DR The Eighth Circuit upheld the conviction of a man who secretly recorded a 15-year-old girl bathing through a bathroom transom window. The court held that even if the suspect's initial consent to surrender his phone was questionable because an officer mentioned obstruction charges, the seizure was nevertheless lawful under the exigent-circumstances exception because officers had probable cause and a reasonable b
Jun 174 min read


The Wrong Man with the Rifle: Fifth Circuit Finds Officer's Deadly-Force Mistake Was Constitutionally Reasonable
Martinez v. Hinojosa, (5th Cir. June 4, 2026) TL;DR The Fifth Circuit held that a police officer who mistakenly shot an innocent man during an active-shooter incident did not violate the Fourth Amendment because the officer's mistake was objectively reasonable under the circumstances. The court found that Officer David Hinojosa reasonably believed Jorge Martinez was the active shooter when Martinez emerged from a house carrying the suspect's rifle during an ongoing police gun
Jun 145 min read


The Four Times She Said She Was 15: Why the Entrapment Defense Failed
United States v. Debevec, (8th Cir. 2026) TL;DR Holding The Eighth Circuit affirmed the conviction of Jayden Debevec for attempted enticement of a minor under 18 U.S.C. § 2422(b), holding that sufficient evidence supported the jury's rejection of his entrapment defense and that the district court properly admitted evidence of internet searches suggesting an interest in minors. Even if admission of certain WhatsApp messages was error, it was harmless. Why It Matters This case
Jun 115 min read


Instagram, Wiretaps, and Rap Videos: How Investigators Built a Federal Drug Conspiracy Case
United States v. Franklin, Smith, Toombs & Duncan, (8th Cir. June 1, 2026) TL;DR The Eighth Circuit affirmed the convictions and sentences of four members of a Kansas City drug-trafficking organization known as "246." The court upheld social media search warrants, wiretap authorizations, the admission of rap lyrics and music videos, and convictions arising from a drive-by shooting connected to the conspiracy. The decision provides important guidance for law enforcement on es
Jun 75 min read


Third Circuit Upholds Hotel Room Drug-and-Gun Convictions Despite Improper Expert Testimony
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
May 264 min read


When a Boxed-In Vehicle Is Still a Deadly Threat: Eleventh Circuit Upholds Deputy Shooting
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
May 225 min read


“He Had the Baby in His Arms” — The Ninth Circuit’s New Deadly Force Decision Explained
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
May 155 min read


Bad Search… Still a Good Case: How Inventory Saved the Evidence
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
May 73 min read
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