W.D.Mo.: Failure to show or leave a copy of the SW or make the inventory in the def’s presence has nothing to do with his statements

“Defendant James Allen Crippen filed a Motion to Suppress Evidence in the matter (Doc. 25) in which he argues that officers executing a search warrant at his home violated Rule 41 of the Federal Rules of Criminal Procedure and the Fourth Amendment by (1) failing to show him the search warrant upon request, (2) leaving the warrant and inventory at his home knowing Crippen was taken into custody and would not have access to it, and (3) failing to prepare the inventory of items seized in Crippen’s presence. Crippen argues that based on the alleged violations, any incriminating statements he made should be suppressed as fruit of the poisonous tree.” Those violations of Rule 41(f) are not constitutional violations, and they don’t have a thing to do with his statements. United States v. Crippen, 2015 U.S. Dist. LEXIS 97476 (W.D.Mo. June 22, 2015), adopted 2015 U.S. Dist. LEXIS 97219 (W.D. Mo. July 27, 2015).

Defendant’s traffic stop was not unreasonably extended. Reasonable suspicion was developing during the 15 minutes it took dispatch to get back, and the return was that defendant was wanted and armed and dangerous. The officer called for backup since there were three people there. The extension of the stop was reasonable. United States v. Anguiano, 2015 U.S. App. LEXIS 13473 (8th Cir. August 3, 2015).

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