E.D.La.: Pursuing fleeing drug dealer into an apartment was reasonable

Pursuing fleeing drug dealer into an apartment was reasonable. United States v. Williams, 2025 U.S. Dist. LEXIS 39113 (E.D. La. Mar. 5, 2025):

This Court finds that the warrantless entry of 1024 Tensas Drive was reasonable under the Fourth Amendment. Officer Bonura credibly testified that he and another officer forced entry into the home because of their concerns about drug crimes occurring in the residence, the destruction of evidence of those crimes, and the safety of the residents of the apartment and themselves. They observed a man involved in drug crimes flee into an apartment, and they were unaware whether he knew the people in the apartment, how many people were in the apartment, or if they were armed. The man that fled into the apartment was certainly aware of the police’s presence and likely informed the other occupants of the apartment of their presence as well. Evidence of drug crimes could easily have been destroyed while officers waited for a search warrant. Accordingly, this Court finds that exigent circumstances justified the warrantless entry of 1024 Tensas Drive. Further, the Court notes that subsequent to the warrantless entry, officers obtained a search warrant. Therefore, the search of 1024 Tensas Drive and the seizure of firearms and drugs from the home was performed pursuant to a search warrant—the validity of which Defendant has not challenged. Accordingly, Defendant’s Motion to Suppress as to 1024 Tensas Drive is DENIED.