M.D.Fla.: Def was a potential suspect in a series of robberies, and he gave cause for an exigent circumstances into a hotel room after he kicked in the door; plain view sustained

An Hispanic male wearing somewhat distinctive clothing committed four robberies around Tampa. Surveillance video put a vehicle at one of the robberies, and officers found it and surveilled it at a motel parking lot. A couple was around the vehicle shouting, and they went inside. Officers observed the male was banging at the hotel room door and finally he kicked it in, and the woman inside yelled out about him having guns. Officers came right behind concerned for her welfare. She was inside crying with a facial bruise. A protective sweep was done. In the course of that, officer saw what they believed were the shoes worn in the robbery. They applied for a search warrant. The shoe was seen during a valid protective sweep, and it supported the search warrant. United States v. Rivera, 2016 U.S. Dist. LEXIS 27852 (M.D.Fla. March 4, 2016).

Defendant was stopped in a Mercedes for overtinted windows. In the car was an iPhone that was being called, and the police answered it, and it was the phone’s owner telling them that he was a carjacking victim, and he described the carjacker. The carjacked car was a Toyota. Defendant was found to have consented to a search of his car that produced clothing matching that of the carjacker. United States v. Caraballo, 2016 U.S. App. LEXIS 4008 (3d Cir. March 1, 2016).*