S.D.Fla.: Threshold arrest led to plain view and risk of destruction of evidence justifying entry

Officers had probable cause to arrest defendant at his house without a warrant, and they only crossed the threshold after seeing drug evidence in plain view when the door was opened, and defendant hesitated like he was going back in. Thus, there was then the added exigency of preventing destruction of evidence. United States v. Jackson, 2014 U.S. Dist. LEXIS 185141 (S.D.Fla. April 16, 2014) (see Treatise § 29.17).

Defendant was cooperative and consented to the police coming in his motel room where incriminating evidence was seen in plain view. United States v. Key, 2015 U.S. Dist. LEXIS 173167 (N.D.Ill. Dec. 30, 2015).*

Expert testimony on defendant’s low IQ and suggestibility were admissible toward the voluntariness of his confession after a consent search and on finding his late father’s gun in the house he shared with his dad before dad died. United States v. West, 2015 U.S. App. LEXIS 22871 (7th Cir. Dec. 30, 2015).*