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Week 40 (2019)

Week of October 21, 2019 through October 25, 2019

Lawrence v. Saul (Diaz 10/24/2019): The Fourth Circuit held that the Social Security Administration properly denied disability benefits to a claimant who could perform work that exists in significant supply in the national economy. The Court found that, because the claimant’s “residual functional capacity” allowed her to perform jobs requiring a General Educational Development reasoning level of two, the claimant was not entitled to disability benefits. Accordingly, the Court affirmed the rulings of the administrative law court and district court. Full Opinion.

United States v. Scott (King 10/25/2019): The Fourth Circuit held that a firearm found by police in the course of a warrantless search should not be suppressed where that search was conducted pursuant to a statutory condition authorizing the warrantless searches of post-release supervisees. The Court held that, although the defendant—in his probation agreement—only consented to searches by his probation officer, the search was not invalid because the statute on which the agreement was based allowed for searches by probation officer. The Court also found that the search was reasonably related to his post-release supervision and was conducted with individualized suspicion of criminal activity. Accordingly, the Fourth Circuit affirmed the district court’s denial of the defendant’s motion to suppress evidence found during the search. Full Opinion.

Highlight Case

United States v. Alston

Decided: October 24, 2019

The Fourth Circuit held that a firearm found during a police search of a vehicle was not the fruit of an illegal search where—irrespective of the defendant’s involuntary statements—police would have inevitably discovered the gun. The Court held that police would have inevitably discovered the gun because police had probable cause to search the car and intended to do so to get the dangerous firearm off the streets. Accordingly, the Court affirmed the district court’s order denying the defendant’s motion to suppress the gun.

A police officer witnessed the appellant, Alston, run a red light and signaled with his lights to tell Alston to pull over. Before Alston did so, the officer saw him reach deep under the passenger seat of his car. After Alston parked his vehicle, he told the officer that he was reaching for his phone under the seat and, when the officer asked him if he had anything illegal in the car, presented the officer with a bag of marijuana. The officer then proceeded to tell Alston that, if he was honest with him and told him what else he had in the car, he would not take Alston to jail. Alston then handed over additional marijuana, a scale, and plastic baggies. The officer then promised Alston once more that he would not go to jail if he was honest and gave up the firearm he had in the car. Following that statement, Alston admitted to possessing a firearm under his passenger seat. Subsequently, Alston entered a conditional guilty plea to possession of a firearm in furtherance of a drug crime, reserving the right to appeal the district court’s order denying his motion to suppress the gun. 

The Fourth Circuit reasoned that, despite the fact that Alston involuntarily admitted to possessing the gun after being promised that he would not be taken to jail, the gun should not be excluded from evidence because of the inevitable discovery exception to the exclusionary rule. Under that rule, derivative evidence is admissible if the prosecution can establish that the evidence at issue ultimately or inevitably would have been discovered by lawful means. Thus, to properly invoke the exception, police must show: first, that police legally could have uncovered the evidence; and second, that police would have done so. 

The Court held that the officer could have legally discovered Alston’s gun under the “automobile exception” to the general requirement that searches be conducted pursuant to a warrant. The Court found that the automobile exception would have been available to the officer because Alston’s voluntary statement about the bag of marijuana gave the officer probable cause to search his vehicle. Additionally, the Court found that the officer would have searched Alston’s car for a weapon because the officer noted Alston reach under his passenger seat while being pulled and suspected that Alston was hiding a firearm. Additionally, the conversation between the officer and Alston during the stop convinced the Court that the officer was committed to keeping a dangerous firearm off the streets. 

Accordingly, the Court affirmed the district court’s order denying the defendant’s motion to suppress the gun. 

Full Opinion.

Fred Hanna