United States v. Watkins a/k/a Crazy Gun: Fourth Amendment Limitations for Public Walkways and Plain View
The Tenth Circuit’s decision in United States v. Watkins examines the limits of Fourth Amendment protections in the context of motel rooms and publicly accessible walkways. The case focuses on whether an officer’s observation through a small gap in motel room curtains constituted an unlawful search. Ultimately, the court concluded that observations made with an officer’s natural senses from a publicly accessible walkway do
United States v. Coleman: Fourth Amendment Guidance on Scope of Consent and Shared Authority
The Seventh Circuit recently released a decision in United States v. Coleman. This case serves as a crucial exploration of Fourth Amendment boundaries, specifically the scope of consent and who can give it. Summary of the Facts On April 20, 2023, around 4:00 a.m., Marshfield Police Officer Jamie Kizer responded to a 911 domestic-violence call. A child in the home reported that Jaison Coleman
Hawatmeh v. City of Henderson: Ninth Circuit Clarifies Standards for Use of Force in Hostage Scenarios
The United States Court of Appeals for the Ninth Circuit recently released a ruling in Hawatmeh v. City of Henderson. This case stems from a volatile hostage situation that occurred in December 2020 after Jason Bourne confronted his neighbors, Dianne Hawatmeh and her daughter Yasmeen, about making a noise complaint against him. Bourne initially walked away without issue but came running after the Hawatmehs
Pena v. City of Los Angeles: Ninth Circuit Clarifies Takings Clause Limits in Police Operations
The United States Court of Appeals for the Ninth Circuit recently released an opinion in Pena v. City of Los Angeles. This case reached the court after an exercise of police power led to private property damage, raising the question of whether it could trigger compensation under the Takings Clause. Carlos Pena owned and operated a print shop in Los Angeles that he used for
Geofence Warrants and the Fourth Amendment: What Chatrie v. United States Could Mean for Law Enforcement
Technology is moving faster than the law, and geofence warrants are one of the clearest examples of that tension. In Chatrie v. United States, law enforcement used a geofence warrant to obtain Google location data connected to devices near the scene of a 2019 robbery. That data helped identify Okello Chatrie as a suspect, but it also raised a major constitutional question: when police
Fuqua v. Santa Fe County Sheriff’s Office: Reassessing Threat Perception and Use of Deadly Force
The United States Court of Appeals for the Tenth Circuit recently released a ruling for Fuqua v. Santa Fe County Sheriff’s Office. This case stems from an incident in July 2021 when Deputy Leonardo Guzman pulled behind Jason Roybal’s vehicle. Knowing that Roybal had outstanding warrants, Deputy Guzman activated his emergency lights to initiate a traffic stop. Instead of pulling over, Roybal attempted to flee.
Balancing the Line: Los Angeles Press Club v. Noem and Constitutional Limits on Protest Crowd Control
The United States Court of Appeals for the Ninth Circuit recently released a ruling in Los Angeles Press Club v. Noem, a case that arose from protests in Southern California. The Ninth Circuit largely upheld protections for journalists, protesters, and legal observers in their decision. However, the Court ordered the trial court to narrow an existing injunction that was found to be too broad
Beyond the Heck Bar: What Olivier v. City of Brandon Means for Enforcement of Protest and Buffer-Zone Ordinances
The Supreme Court recently decided Olivier v. City of Brandon, holding that a plaintiff with a prior conviction under a law may still bring a Section 1983 suit seeking purely prospective relief against that law, and that such a suit is not barred if the plaintiff lacked access to federal habeas relief. Summary of Facts Gabriel Olivier, an evangelical Christian street preacher and anti-abortion
Four Minutes, Two Taser Deployments, and a Fatal Shot: Burke v. Pitts Reaffirms That Qualified Immunity Has Limits
The United States Court of Appeals for the Tenth Circuit recently released a ruling for Burke v. Pitts, a case that arose after a response to a domestic disturbance call ended with multiple Taser discharges and a fatal shooting within four minutes of officer arrival.1 The United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity for the officers, holding that, under clearly established law, the officers’ use of force was
Wristlocks, Warnings, and Qualified Immunity: What Zorn v. Linton Means for Officers
The Supreme Court of the United States recently decided Zorn v. Linton, holding that, because the U.S. Court of Appeals for the Second Circuit failed to identify a case where an officer using a routine wristlock on a protester after issuing a verbal warning, without more, was held to have violated the Constitution, Sergeant Jacob Zorn was entitled to qualified immunity. Summary of Facts
Waffle House, Warrants, and a Weak Nexus: What Wilson Means for Fifth Circuit Officers
The United States Court of Appeals for the Fifth Circuit recently decided United States v. Wilson, a case emphasizing that a search warrant affidavit must establish probable cause specifically tied to the place to be searched, and that assumptions or mere proximity alone are insufficient to justify a search. Summary of Facts In April 2023, Ricky Wilson was allegedly eating at a Waffle House
No Privacy in an “Out of Order” Restroom: Seventh Circuit Affirms Warrantless Entry and Constructive Possession in United States v. Scott
The United States Court of Appeals for the Seventh Circuit recently released an opinion in United States v. Scott, a case highlights reasonable expectations of privacy in the context of public restrooms and constructive possession of a firearm. New Feature: Training Shorts (BETA) Try Training Shorts, our newest training feature. This AI-powered tool automatically pulls key takeaways from our Legal Updates, giving you a