Search and Seizure Cases
United States v. Weaver
U.S. Court of Appeals for the Fifth Circuit
25-60269
April 2, 2026
Summary: Good-Faith Exception applied where search warrant affidavit contained sufficient factual detail to justify an officer’s reasonable reliance on the warrant, and Miranda waiver was voluntary even without reading the form aloud.
Law enforcement officers executed a search warrant at a residence in Starkville, Mississippi, after an officer obtained the warrant through an affidavit detailing three controlled drug purchases involving a confidential informant. The affidavit described the procedures followed during the buys, including continuous surveillance of the informant and searches for contraband before and after each transaction. The search resulted in the seizure of drugs, firearms, money, and cellphones, and the resident was arrested. During a subsequent police interview, the resident was read his Miranda rights and signed a form acknowledging this, but the waiver portion of the form was not read aloud or explained.
The United States District Court for the Northern District of Mississippi granted the defendant’s motion to suppress both the physical evidence from the search and the statements made during the interview. The district court found the supporting affidavit for the search warrant to be “bare bones,” lacking sufficient detail or corroboration, and concluded that the officer’s reliance on the warrant was not objectively reasonable. The court further found that the defendant’s signature on the Miranda form did not amount to a voluntary waiver of his rights, as the waiver section was not explained and the officer’s conduct was considered deceptive.
On appeal, the Fifth Circuit held that the good-faith exception to the exclusionary rule applied because the affidavit was not “wholly conclusory” and contained sufficient factual detail to justify an officer’s reasonable reliance on the warrant. Thus, the suppression of the physical evidence was reversed. Regarding the statements, the appellate court agreed that the express waiver was involuntary but remanded for the district court to determine whether an implied waiver occurred under the totality of the circumstances. The panel retained jurisdiction pending the district court’s further findings.
United States v Watson
U.S. Court of Appeals for the Seventh Circuit
24-2432
April 2, 2026
Summary: Federal warrant was based on evidence that was untainted by illegal evidence, and therefore was admissible under the independent-source doctrine.
The defendant was indicted under federal law for possessing firearms after having been previously convicted of felony offenses, including possession of cocaine with intent to distribute and being a firearm user while using controlled substances. The case arose when police, investigating a shooting, traced evidence to the defendant through witness statements, storage unit searches, and DNA samples. The defendant challenged the admissibility of DNA evidence.
The United States District Court for the Eastern District of Wisconsin denied the defendant’s motions to dismiss the indictment and to suppress the DNA evidence. The court found that the DNA collected by federal authorities was obtained independently of any potentially unlawful prior collection by state authorities, and that there was a sufficient evidentiary basis for the federal warrant. The defendant subsequently pleaded guilty but preserved his right to appeal the denial of his motions.
On appeal, the Seventh Circuit affirmed the district court’s rulings, holding the DNA evidence was admissible under the independent-source doctrine, as the federal warrant was based on evidence untainted by any prior illegality. The judgment was affirmed.
United States v. Isham
U.S. Court of Appeals for the Eighth Circuit
24-3432
April 1, 2026
Summary: Defendant was in arrest-like custody when questioned in response to a domestic violence 911 call.
Mark Isham and C.K. were in a long-term relationship, living together intermittently. In March 2023, after C.K. stayed with Isham following her release from a treatment center, the two drank alcohol and argued, resulting in Isham physically assaulting C.K. on two separate occasions. Several days after the second assault, C.K., who is an amputee, called 911 and reported being held against her will and physically abused. Police officers responded to Isham’s home, spoke separately to both individuals, and eventually arrested Isham after he admitted to hitting C.K. C.K. was hospitalized and required surgery for a fractured jaw.
At trial, Isham sought to suppress the statements he made to officer’s prior to being arrested. The court denied Isham’s motion to suppress, concluding he was not in custody during the questioning. At trial, the jury convicted him of assault resulting in serious bodily injury and assault resulting in substantial bodily injury to an intimate partner.
On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the judgment of the district court, holding that Isham was not subjected to custodial interrogation before his arrest, as the questioning was brief, non-coercive, and Isham voluntarily participated.
United States v. Kaeding
U.S. Court of Appeals for the Eighth Circuit
24-3462
March 27, 2026
Summary: Defendant was not in arrest-like custody for Miranda purposes during the initial interview.
The case concerns a defendant who, during the early months of the COVID-19 pandemic, submitted multiple fraudulent applications for Paycheck Protection Program and Economic Injury Disaster Loans using false information and forged documents. The defendant, with family members, obtained over $650,000 in loan proceeds by falsely representing the status and finances of various companies. Law enforcement executed a search warrant at the defendant’s home, conducted an interview, and discovered evidence of fraud. The defendant fled to Colombia, prompting an international effort that resulted in his apprehension and extradition to the United States.
The United States District Court for the District of Minnesota presided over pretrial matters, including the defendant’s motion to suppress statements made during the home search. The court denied the motion to suppress, finding the defendant was not in custody during the interview. The jury convicted the defendant on all counts.
On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment, holding the defendant was not in arrest-like custody for Miranda purposes during the initial interview.
State v. Porter
Iowa Supreme Court
24-1254
March 27, 2026
Summary: Search of the backpack was within the scope of the premises warrant when it was not in the physical possession of anyone at the time of the search, defendant denied ownership, and it was a place where the evidence sought could be found.
Peace officers developed probable cause to believe that controlled substances were being distributed from a house in Des Moines. After conducting multiple controlled buys, officers obtained a premises search warrant for the house. On the morning the warrant was executed, Andrew Porter arrived at the house carrying a backpack. About forty minutes later, officers entered and found Porter in the living room; the backpack was in a corner, not within his immediate reach. During the search, Porter repeatedly denied ownership of or knowledge about the backpack, both when questioned outside and inside the house. Officers searched the backpack and found methamphetamine, marijuana, and drug paraphernalia. Porter was arrested and charged with several drug offenses.
Porter filed a motion to suppress the evidence obtained from his backpack, arguing that the search violated his constitutional rights under the Fourth Amendment and the Iowa Constitution. The Iowa District Court for Polk County denied the motion after reviewing evidence, including bodycam footage.
On appeal, the Supreme Court of Iowa addressed whether the federal or state constitutional right to be free from unreasonable searches prohibits officers executing a search warrant from searching a container on the premises, such as a backpack, capable of holding evidence described in the warrant, when the container is not in a person’s physical possession. The court held that the search of the backpack was within the scope of the search warrant because it was not in Porter’s physical possession at the time of the search and was a plausible repository for the evidence sought. The court further found that Porter’s repeated denials of any connection to the backpack constituted abandonment, negating any privacy interest. The court affirmed the district court’s denial of the motion to suppress.
Use of Force and Officer Liability Cases
Baker v. Coborn
U.S. Court of Appeals for the Fifth Circuit
25-10545
March 27, 2026
Summary: Qualified immunity precluded where officer’s second round of shots at vehicle arguably constituted a clearly established violation of the Fourth Amendment.
Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, and then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.
The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled that the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded the case for the district court to decide whether the right was clearly established.
On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established and the officers again appealed. On appeal, the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Accordingly, Coborn was not entitled to qualified immunity at the summary judgment stage for the second round of shots.
Aaron v. King
U.S. Court of Appeals for the Sixth Circuit
25-1629
April 1, 2026
Summary: Officer’s use of force taking suspect to the ground and kneeing him did not violate clearly established rights.
After a series of violent crimes in Detroit, including a gas station robbery and a home invasion, police identified Derek Aaron as the primary suspect based on witness descriptions, security footage, and phone records. Officers located Aaron at a local gas station, where they attempted to arrest him without explicitly informing him of the arrest. Aaron, a large man, resisted by refusing to place his hands behind his back, repeatedly asking for an explanation, and physically pulling his arms away. The officers responded by taking him to the ground and using knee strikes to subdue him before successfully handcuffing him. Subsequent criminal charges against Aaron were dismissed, possibly due to his autism diagnosis, which was unknown to the officers at the time.
Aaron, through his legal guardian, filed suit in the United States District Court for the Eastern District of Michigan, alleging that the officers used excessive force during the arrest and that other officers failed to intervene. The officers moved for summary judgment on the basis of qualified immunity. The district court granted qualified immunity on the failure-to-intervene claims but denied it on the excessive force claims, finding that a jury could determine the officers violated clearly established rights. The officers appealed the denial.
On appeal the Sixth Circuit reversed the district court’s denial of qualified immunity on the excessive force claims. The court held that, given the seriousness of the suspected crimes, Aaron’s active physical resistance, and the absence of a clearly established legal prohibition against the officers’ conduct under similar circumstances, the officers did not violate Aaron’s clearly established constitutional rights. Therefore, the officers were entitled to qualified immunity, and the district court’s order was reversed.
Cunningham v. Olson
U.S. Court of Appeals for the Eighth Circuit
24-3261
April 2, 2026
Summary: Plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train to preclude immunity.
A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.
Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. In federal court, the superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.
On appeal, the Eighth Circuit held that the current superintendent was a proper defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity.
Manning v. City of Tulsa
U.S. Court of Appeals for the Tenth Circuit
24-5058
March 30, 2026
Summary: The use of deadly force against an unarmed, non-threatening individual is clearly established as unconstitutional.
A Tulsa police officer, while responding to a call in September 2016, encountered Terence Crutcher, an unarmed Black man who was behaving erratically. Officer Shelby initially passed Crutcher but stopped after seeing an abandoned SUV in the road. As Shelby investigated the vehicle, Crutcher approached with his hands raised. Shelby, joined by another officer, issued commands to Crutcher, who was slow to comply but largely kept his hands up. As Crutcher reached the SUV, Shelby shot him, and another officer simultaneously deployed a Taser. Crutcher died from the gunshot wound.
The administrator of Crutcher’s estate filed suit in the United States District Court for the Northern District of Oklahoma, alleging excessive force under 42 U.S.C. § 1983 against Shelby, as well as claims against the City of Tulsa under state law and Monell v. Department of Social Services for municipal liability. The district court dismissed the Monell claims for failure to state a plausible claim of municipal liability. Subsequently, it granted summary judgment to Shelby on the basis of qualified immunity, concluding that the constitutional right at issue was not clearly established. With no remaining federal claims, the district court dismissed the state-law claim without prejudice.
On appeal, the United States Court of Appeals for the Tenth Circuit reversed the grant of summary judgment to Shelby, holding that the district court erred by not viewing the evidence in the light most favorable to the estate and by defining the clearly established right too narrowly. The court found that, under long-standing precedent, using deadly force against an unarmed, nonthreatening individual is clearly established as unconstitutional. However, the Tenth Circuit affirmed the dismissal of the Monell claims, concluding that the estate failed to plausibly allege municipal liability.
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