Law School Case Brief
United States v. Bain - 874 F.3d 1 (1st Cir. 2017)
Good faith reliance on a warrant procured and issued in good faith saves the fruits of a warranted search from suppression.
The police arrested Defendant Yrvens Bain after he emerged from a multi-family building in Malden, Massachusetts. During the search incident to that arrest, they found a set of keys in defendant's possession. The police tried these keys on the front door of the multi-family building and on the doors to three apartments inside--one on the first floor, two on the second floor. The keys opened the door to one of the units on the second floor. The police included this information in an application for a warrant to search that unit. The warrant issued, and the search produced a firearm and over 26 grams of heroin mixed with fentanyl. Bain moved to suppress that evidence. He argued, among other things, that the officers conducted an unlawful search by turning his key in the locks to identify the unit to search, and that there was no probable cause to issue a warrant to search the unit without that identification. The district court denied defendant's motion, and Bain was convicted. Defendant appealed, arguing that the search was unlawful.
- Was the officer’s search unlawful?
- Should the evidence obtained pursuant to the search be declared as inadmissible?
The Court of Appeals for the First Circuit held that the officers conducted an unlawful search by testing the key in the lock of the unit in which Defendant Bain was staying. However, the unlawfulness of the search would not render the fruits of such search inadmissible as the officers relied in good faith on the intervening warrant. Furthermore, the Court held that, although the district court should have suppressed the officers' testimony about using Bain’s keys to open the door to the apartment immediately after his arrest, admitting the testimony was harmless because the remaining evidence was so overwhelming that the jury would have concluded that Defendant possessed the drugs and gun in the apartment even if the district court had excluded the testimony about his keys.
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