W.D.Mo.: Primary object of SW found right inside front door, but that didn’t preclude larger search

The search warrant was for a package found right inside the front door. That did not preclude the officers from searching further in the house. Also, a protective sweep incident to execution of the search warrant was proper. Searching inside a shoebox on a dresser under the protective sweep would be inappropriate, but there was a search warrant, and that validated the search. United States v. Green, 2019 U.S. Dist. LEXIS 80528 (W.D. Mo. May 14, 2019).

The jury could conclude that the person who hid the cocaine in the outbuilding as the police approached to execute a search warrant was defendant, and that supports his conviction. United States v. Napolis, 2019 U.S. App. LEXIS 14234 (11th Cir. May 14, 2019).*

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