Legal Update

Ninth Circuit Rejects Fifth Amendment Compulsion Theory Where Police Properly Mirandize in United States v. Watson

In a recent case, the United States Court of Appeals for the Ninth Circuit released a decision in United States v. Watson, a case that highlights a parolee’s rights during law enforcement investigations and considers the boundaries of compelled statements under the Fifth Amendment. Summary of the Facts In May 2022, Federal Drug Administration agents and the Nampa Police Department began investigating Tyler Jay […]

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Bytes and Bounds: Holcomb’s Warning Against Unfettered Electronic Searches

The United States Court of Appeals for the Ninth Circuit issued a decision in United States v. Holcomb, 23-469 (9th Cir. 2025), where the Court considered “whether an individual can be prosecuted for despicable criminal conduct based on evidence obtained in violation of the United States Constitution. Ultimately, the Circuit wrote, “In the circumstances of this case, respect for the Constitution and the rule

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Confession or Coercion? Constitutional Clarity in United States v. Maytubby

The United States Court of Appeals for the Tenth Circuit recently decided United States v. Maytubby, a case that evaluates whether a confession obtained during a police interview was voluntary under the Fifth Amendment, highlighting an example of how courts assess officer conduct and potential coercion during non-custodial interviews. In December 2020, Lance Maytubby was questioned at a police station following allegations of sexual

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Handcuffed on the Strip—Court Rules Visible Glock Justified Extra Restraint During Traffic Stop

The Ninth Circuit Court of Appeals recently issued a decision in United States v. In, 124 F.4th 790 (9th Cir. 2024), after the defendant, Larry In, was charged with being a felon in possession of a firearm following a traffic stop conducted by officers of the Las Vegas Metropolitan Police Department. This case offers essential guidance for law enforcement officers, considering the proper scope of

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Six-Second Shooting Strips Seattle Officers of Immunity — Ninth Circuit in Johnson v. Myers

The United States Court of Appeals for the Ninth Circuit issued a decision in Johnson v. Myers, 129 F.4th 1189 (9th Cir. 2025), where the Court considered whether a suspect posed an immediate threat to officers for purposes of determining whether the officers’ use of deadly force was justified. The case reached the Court after Ryan Smith was shot and killed by two Seattle police

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Timing Tossed, Totality Triumphs: SCOTUS in Barnes v. Felix Clarifies Use-of-Force Analysis

On May 15, 2025, the Supreme Court of the United States released its long-anticipated opinion in Barnes v. Felix, S.Ct.., 2025 WL 1401083. The unanimous 9-0 decision clarified and reiterated several critical principles for assessing use of deadly force cases. A police officer’s use of deadly force violates the Fourth Amendment when it is not “objectively reasonable.”[1] The inquiry into reasonableness requires assessing the

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AI in Law Enforcement: Innovation, Risk, and the Road Ahead

The Future of AI in Law Enforcement The Guardian Mindset Podcast is back with a critical conversation on Artificial Intelligence in Law Enforcement. Attorney Eric Daigle sits down with Attorney Joseph Race, an expert in policy and accreditation, to break down the real-world implications of AI in policing. From predictive analytics and real-time crime centers to the legal minefield of facial recognition, this episode

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Medical Emergencies as Legal Crossroads: United States v. Hudson and the Fourth Amendment in Hospital Settings

The Seventh Circuit’s recent decision in United States v. Hudson navigates complex Fourth Amendment issues within the context of medical emergencies and law enforcement intervention. This case focuses on the complexities involved when the duties of medical personnel and police officers intersect. The case began on an early morning in January 2022, when Javares Hudson arrived at Carle BroMenn Medical Center seeking emergency treatment

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Dividing Lines: The Fourth Circuit’s Take on Geofence Warrants in United States v. Chatrie Amid Growing Circuit Split

In July 2024, the United States Court of Appeals for the Fourth Circuit issued an opinion in United States v. Chatrie, a case that could potentially make its way up to the Supreme Court of the United States, providing the High Court an opportunity to settle an existing circuit split over the constitutionality of geofence warrants as an investigative technique used by law enforcement.¹

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Midnight Missteps: The Limits of Reasonable Suspicion in Milla v. Brown

In the recent case Milla v. Brown, the United States Court of Appeals for the Fourth Circuit examined Fourth Amendment claims lodged against two officers for detaining and searching the plaintiff and his vehicle without adequate reasonable suspicion to justify the detention. After receiving an anonymous tip about a nearby stabbing, police in Fairfax, Virginia, responded to a gas station, which was reported to

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