The U.S. Marshal’s fugitive task force, with arrest warrant in hand, was looking for defendant. They were watching his motel room and saw him outside and gave chase. They lost sight of him and circled back to his hotel room and entered it on the arrest warrant, which was valid under Payton. The officers reasonably believed he got back there before them. There was sufficient exigency for a protective sweep. United States v. Ross, 2017 U.S. Dist. LEXIS 184239 (N.D. Fla. Nov. 7, 2017).
Defendant was subjected to a New York State parole search, and it was otherwise valid. After four weeks, officers got a search warrant and came back and seized a cell phone, among other things. The government relies on inevitable discovery that the phone would still be in the same place after four weeks, and the court requires a hearing for the government to establish that and for the defense to explore whether the deterrence rationale of the exclusionary rule applies. United States v. Robinson, 2017 U.S. Dist. LEXIS 182889 (E.D. N.Y. Nov. 1, 2017).*