A ruling on a motion to suppress during the proceedings is subject to change. It is not governed by res judicata because it isn’t final. United States v. Baez, 2018 U.S. Dist. LEXIS 184017 (D. Minn. Aug. 30, 2018), adopted, 2018 U.S. Dist. LEXIS 183647 (D. Minn. Oct. 26, 2018).
Officers had probable cause for defendant’s arrest and he fled, and they followed in hot pursuit into his house. “Defendant created the exigent circumstances by disregarding law enforcement’s commands to stop, grabbing his waistband, turning away from the officers, running inside the house, and closing the door.” A protective sweep was valid. United States v. Brown, 2018 U.S. Dist. LEXIS 185187 (S.D. Fla. Oct. 30, 2018).