The Search & Seizure Show

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Hello, everyone, it's Anthony Bandiero here with blue to gold law enforcement training, bringing to the roadside chat. All right. So our question today comes from an officer in the great state of Tennessee. I Love Tennessee. All right. So here's the question. Can a tenant in a government housing project waive their Fourth Amendment protections of the home by lease agreement? Okay. Let me give some context. So the officer sharing here that in our local housing authority, it is my understanding that the manager can enter and search a tenants apartment anytime, under the lease agreement. On occasion, they have asked that we stand by while they do so. And have even asked for Kane for canine to sniff the apartment. Does this violate the Fourth Amendment? Or does the lease agreement act as it as act as consent? Alright, so the, the quick answer is, can the government housing project waive a person's fourth amendment rights?

And the answer is no. Because no government agency can basically tell a person you have no more fourth amendment rights, right? If you're going to take if you're going to subscribe to this or, you know, accept these government benefits, you have no fourth amendment rights, that's not the way to look at it instead. The question is, okay, are they asking for something that is reasonable? Right, if it's reasonable, it likely complies with the fourth time, it's not like the government, government housing projects have no have no authority to inspect their property to make sure that people are not abusing the property. And, you know, if they get a tip that something's manufacturing drugs or so forth, that they can't do anything about it. But the point is, still, is that is that a waiver of the Fourth Amendment? No. Is it potentially reasonable under the Fourth Amendment? Maybe? So let's go through it. So number one, apparently, right, or allegedly, the lease agreement says that we can come into your apartment anytime and inspect. I doubt that's the case. Right? If that if it truly said that we can come into your apartment anytime and you know, without notice, or without any kind of just cause I doubt a court would uphold that. Because that is not reasonable. Right? You are the government and you're in you're offering these benefits. And you're saying as a stipulation to accepting the benefit, I have to allow the government's right, you know, aka the Housing Authority, the law, the government to come into my home and just rummage through my stuff or just inspect my property? No. So I doubt that that's the case...

Alright guys, today's question comes from an officer in Texas and asked me, Can you trespass? Someone sleeping in a rented storage unit, I am sure that all of you have run into something similar. So Now, usually I don't touch statute issues. I'm a search and seizure guy. But I think I can address this when I see them being pretty straightforward.

And the answer is, yes. I think that this ties in with search and seizure, because we have a lot of debates today about, you know, when Pete When homeless people have nowhere to go, you know, police options are sometimes limited. But we're when we're talking about those cases, Martin versus Boise, for example, out of the Ninth Circuit, we're talking about situations of public property, right? There is a debate going on around the country, where if homeless people do not have a place to go, and they're sleeping in parks, and so forth, and under bridges, and cops want to trespass them and move them along. The question for the courts becomes where, right, okay, you want to move them from here to there? Or move them? And then where, right? Where can they go? Is there a shelter available, if there's not a shelter available is another place that they can go like a designated urban camping spot. So that's kind of where I think the flavor is coming from. But normally, we don't have those issues when it comes to private property. Now, the storage unit is not a hotel, it's not sanitary, there's no bathrooms. It's just, you know, the it's not safe, frankly, for safe and sanitary, sanitary, for people to be sleeping in storage units. So this the, if the rental storage unit, you know, manager wants to kick these people out for improper use of the storage unit, I see no problem at all, for criminal trespass, for my understanding of Texas law, but you know, even a lot of places, it's just not going to be a lawful use of the premises. So therefore, they can be trespassed, I think it's a pretty straightforward question. I understand. I'm going to also again, give a little spin about how to look at it through the eyes of maybe some search and seizure issues because of the homelessness problems pervasive around the country. But again, I don't think that's going to change the outcome here. I think that the storage unit absolutely has the right to keep people out of their storage unit living in there, and they can be trespassed for it. Alright, so pretty straightforward answer, hopefully move the ball forward a little bit before you guys go. Do me a favor, hit like, please hit subscribe, and tell your friends about us. Alright, until next time, my friends stay safe.

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The following is a computer-generated transcription, some grammar and spelling errors may be inherent

Alright guys, this is a question that comes up a lot. It is when can we enter a home after a 911? Hang up? Right? I shouldn't really say 911 Hang up. And let me give you some context here from my email. All right, there's officers from Texas, you know, we often get sent to Nemo and hang up calls with no information provided by the caller. When we get on scene and someone answers the door, they typically tell us everything is fine. You know, inside it was also it was an accident. My question is, at what point do we have an obligation to go inside the home to check on the welfare of others. So the cop will typically ask if there's anyone else inside. And if they say no, and the cop doesn't have any reason to believe anyone else is inside there, then the officer concludes the investigation leaves. Now they tell the officer that someone is inside, I let them know that I want to check on the person to check on their welfare, and typically give them the option of bringing them to the cop right to the door, or the COP is going to potentially make a forced entry and walk past the husband, let's say and go check on people. Now, let's say that we get a 911 Hang up. And upon meeting the caller at the front door, we are informed it was an accident that they dialed 911 and everything is fine. They then tell us that there are other people inside but no emergency exists. We don't see anything that would indicate an emergency. I don't hear anything that would give us exigent circumstances to enter the home. The question is, are we obligated to check on the rest of the residents welfare inside the home? And if we enter the home without consent or any other agency, would that be violating the person's rights? All right. This is a great question. And you know that this comes up all the time. So let's just kind of address it now. First of all, the laws, you know that the officer can recognize that he's did some research and the case was a little over the place. I will say that the majority of the cases seem to be supportive of the officer's actions. Right of going in of making sure that people okay nama one hangups, you know, can be pretty serious. But this is 2021. This is not your grandparents Police Department. There are a lot of stuff going down today that was would never have gone down even 10 years ago. So the game that we're playing today is way more advanced is way more protective of your liability. Okay. So with that said, Here's what I teach. Number one. What is the rule? The rule is this falls under the emergency aid exception. This is not a does not fall under community caretaking. We know that community caretaking does not apply to homes. Right, we have that from a US Supreme Court case called Coniglio versus strong caretaking Communicare taking is a pretty a relatively low standard where cops just want to make sure that people are okay; that's not the standard that we use anymore. We are definitely in the ballpark of exigency emergency urgency, and that falls under the emergency aid exception. So, therefore, in order for you to push past the husband, for example, and check on the occupants, you're going to be able to need to articulate some ongoing emergency where time is of the essence...

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Alright guys, this question comes from an officer from Florida and basically the idea is the Carroll doctrine. Concerning passenger's property. Let me kind of read a little bit about about about the background for my email, give you some flavor what's going on. Alright, so officer in Florida had a traffic stop, right? For expired registration, now made contact with the driver and the passenger, who are both not the registered owners of the vehicle. The driver provided an expired with his license but learned later that it was suspended. The passenger provided an ER name, but no license and is also making it clear that they cannot search nobody can search her stuff, nor the car. Now she has a warrant, but we learned later that the warrant is not extra but extraditable about where they're at. So it's not going to be executable. Alright, so while hold on me. All right, there also the tag attached. The vehicle was not assigned to the tag on the license plate is not assigned to the vehicle. So there's all kinds of things going on. There's no canine available. Now the vehicle is inventorying for towing in plain view on the driver's side floor was a crack pipe, and then plain view. When the doors open open, we also see a US needle in the storage compartment, a book bag that the driver was holding. My first approach was searched, drug paraphernalia were found in some cocaine, the driver was charged appropriately. Now what we're going to be talking about here is what about the passenger? Right? The passenger also has some property. And can that now the passenger admits that hold on the passenger Okay, he's the pastor saying, hey, you know, the needle can't be the drivers because he's snorts his cocaine doesn't shoot a needle. But apparently, she admits that she uses needles. Right. But also, the needles might belong to the owner of the car. So the question is, could the passenger's purse be searched? Under the Carol doctrine, the motor vehicle exception is based on the totality of circumstances, alright. Hope you got a flavor what's what's kind of going on? But alright, so here's the deal. Okay. So, generally speaking, the passengers items fall under the Carol doctrine. So passengers don't fall under the Carol doctrine like passengers are not searchable under the motor vehicle exception. Instead, you have to have probable cause as to them whether you have probable cause here; that's not the question the COP is asking. So I won't address it. But we do know, from a case, I think it's called Wyoming versus hufton. Maybe not be saying that correctly. But it's Wyoming versus the US Supreme Court. And the US Supreme Court stated that if police have probable cause for the car, that they can also search those areas where they reasonably believe more evidence could be found. Well, okay, that's the question for us here. Do we believe that more evidence of the drugs could be found in the passengers? Purse? And I believe the answer is yes. But the way that you answer this question is another case. So we know that passenger stuffs our belongings are fair game if you have probable cause. Well, that brings us to another case called us versus Ross. And they're the US Supreme Court says that you search a car in the same manner as if you had a warrant. My question for you then is this. Do you think, based on the circumstances that the cop if he or she wanted to, can go get a warrant for the car in

for the purse? If the answer is yes, then you search the car, you search the purse? If the COP is unsure, then you probably shouldn't search the purse because you don't have your probable cause. In other words, what would you articulate? Is that make sense? That's kind of what we're looking at here...

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Alright guys, welcome to another roadside chat. Today's question is, from an officer in Indiana, would the single purpose container doctrine allow cops to search a vehicles hidden compartment? Alright, so the first thing we want to learn is what is a single purpose container? Okay, a single purpose container is this doctrine that basically says some containers by their shape by their manner of under totality circumstances, the way that they're kept, the what they're packaged in. Things on the outside, are so telling of what to contain what the contents are, that a reasonable officer would know that only contraband is inside. So that's a roundabout way. So in other words, a single purpose container is a container that announces its contents in a manner that only contraband is inside. Okay, the why this is important. This is important because under the Fourth Amendment, in order to search a container, you have to have usually probable cause plus probable cause, plus search incident to arrest probable cause plus motor vehicle, probable cause plus consent, probable cause plus exigency. In other words, there is no such thing as searching a container based off a probable cause alone, it doesn't exist, it's a unicorn. So single purpose container doc doctrine basically saves some of these searches, it allows, because the way that the Supreme Court looks at it is that a single purpose container would not have any privacy interest, and so forth. Let me give you an example of a single purpose container, a drug package, right? A brick of cocaine. It's wrapped up in, you know, paper or duct tape and so forth. Can you see inside of it? No. But do you know that it's packaged in a way that only contraband is inside? Yes, therefore, you don't need any other reasons to search it. The reason the package containing contraband is enough, but don't be fooled, because sometimes you'll have probable cause that a container has contraband inside. But it's not a single purpose container because it could have something else like so for example, there was a case involving a cooler, and the cop smelled the marijuana emanating from the cooler and the cop opened the cooler and found marijuana. But the problem is the under this situation, the cooler was not near the guy wasn't search incident to arrest it wasn't part of the motor vehicle. The problem is that there was no other reason to get into the cooler because it was not a single purpose container. The cooler could have other things in it nonconscious ban bologna sandwich, Capri Suns, you get my point, not just marijuana in at this time was it was contraband. Alright, so now we get to the cops question, would the single purpose container doctrine allow cops a search of vehicles hidden compartment? Other words? Could the hidden compartment be viewed as a single purpose container? The answer is most likely not. I don't have any cases on it. I haven't seen it. But I don't really see courts, or at least prosecutors applying the single purpose container to hidden compartments of a vehicle. And here's for good reason. Frankly, you don't need the single purpose container doctrine to save the day for the searches. Why? Because the COP is going to have probable cause anyway. And if you have probable cause plus motor vehicle, that is the motor vehicle exception, why not just use that? Forget the whole more complicated argument about single purpose container? So that's really the answer here. We don't need the single purpose container to even search the hidden compartment because you're going to have if you have probable cause you have probable cause and just use the motor vehicle exception. All right...

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Hey guys, it's Anthony here, bringing in a roadside chat from the road. Actually, I'm in Joplin, Missouri this weekend. It's actually really nice to be out here. And it's a beautiful place. So this question comes from an officer in Alabama. And he says, Can a subject be interviewed after invoking Miranda, on a separate case, by a different agency. And so the kind of the backstory is a suspect was arrested by a neighboring department. They went into interview him, but he said he wants to have an attorney. Now, this officer wants to read, you know, give him Miranda again, and interview him on a different case.

And here's the answer, the answer is that according to the US Supreme Court, this guy is off limits for any interview, regarding anti any crime for 14 days, post Miranda custody, alright. So this rule makes a little bit difficult for cops to get to interview people after they invoke the right to counsel. So there's a couple things going on. Number one is this 14 day rule, the 14 day rule comes from a US supreme court called Chester, where they made a bright line rule normally Supreme Court that doesn't make bright line rules, but here they did. So it's a bright line rule that if the guy invokes the right to counsel, he's off limits for 14 days, post Miranda custody, what does that mean? Post Miranda custody? Well, being in Miranda custody is a totality of circumstances tests that ask whether or not a reasonable person would believe custodial, like arrest exists. And the cops are asking questions, which are likely to elicit an incriminating response. So that's kind of like your arrests, you know, during the booking process, and so forth. But when does a person leave Miranda like custody? Well, if they're released from jail, certainly, that is easy. If they're put into general population, we don't have a lot of court cases on this. But if they're put into general population with other inmates, and they're going to be held for a while, this is not like a holding cell. But this is like their new home until they get bail money, or maybe they're just waiting trial, there's the best argument is that they are not in arrest, like custody at that point, because jail is now their home, we certainly know that. That prison is the person's home, and a person is not in Miranda custody, while they're serving a sentence in prison, it's less clear in jail, but I think the best advice I have for you is that, you know, let the person you know, if he's in general population, you know, let him have his 14 days, and then re mirandize him and see if he will talk now you don't need to talk to an attorney if you're talking about a different crime. But if you're talking about the same crime or any criminal act, you know, any crimes that can be related to that one he's been held on, he's off limits, period, basically, until he talks unless you have his attorney present, and the PERT and the attorney signs off on it. This rule sometimes has consequences that are not really logical like so for example, the cop here wants to talk to a guy about a different crime different agency. But yet, he's off limits for 14 days. ,,

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The following is a computer-generated transcription, some grammar and spelling errors may be inherent

Hey guys, it's Anthony Bandiero Here, attorney, Senior Legal instructor at Blue to Gold. Okay, so been really busy. I'm going to be putting out more of these videos as as we go forward here. But I'm outside of Cleveland, Ohio delivering our advanced search and seizure classes. And hopefully you've attended one of our classes. If not, please sign up online. Also, we traveled the country. Today's question comes from an officer in New York. And he was reading my book, the search and seizure Survival Guide. And he said, Hey, you know, you mentioned an automatic pat down in your book, what is an automatic pat down, you know, and just kind of give you some more context, and he wanted more context to understand what I was talking about. First of all, I'm glad he reached out because I don't normally use the word automatic anything. When it comes to the Fourth Amendment. There really are no automatics. I mean, everything is based on something else, like a search incident to arrest. Okay, it's automatic, right? I mean, you get to search somebody's incident to arrest, but it's not automatic in the sense that you have to have a lawful arrest. If you don't have a lawful arrest, then the search would be invalid to be for the poisonous tree. But what I mean by automatic pat downs is that when you're dealing with violent people who are suspected of violence, and that crime is is suspected of being involved with a weapon, then pat them down. Right? That's an automatic pat down. So violence plus weapon I mean, this is when you think about it, it's like okay, Anthony, that makes that makes sense. Obviously, I'm going to pat down somebody who I believe is violent and also has a weapon. And the reason why I call it automatic is because it instantly satisfies Terry, right? Terry versus Ohio has two requirements you know for pat downs right? It says that the person is considered armed and dangerous. Well, if they're if you believe that they could have a weapon, there's the arm check and dangerous if you believe that they've committed violence against somebody else, and they have a valid temperament Right? Or some other factors that believe that they could engage in a violent act on you well, there's the dangerousness equals pat down. So when you serve out these guys, you're gonna you're gonna pat them down, you're still going to articulate it, you're not going to use the phrase you know, I then conducted an automatic pat down in your report Don't say stuff like that the court will push back on you and say look, you know, what do you mean by automatic right? Say that I conducted a pat down because the person was believed to be involved in a violent crime such as you know, sexual assault and the report to be abused the weapon I you know, ie a knife gun, you know, some kind of striking device, you know, and so forth. So, that's what I mean. Alright, so there you go. Keep the questions coming hopefully adds a little more context to my viewer in New York, or my reader in New York and also some other cops guys, keep these questions coming. Please hit the Like button. let YouTube know if you find these videos, valuable. Comment. Any comments are great, you know, feedback for me and for the rest of the viewers. And finally, stay safe out there and keep up the good work. Thank you.

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Alright, hey guys, it's Anthony Bandiero Here, attorney, Senior Legal instructor for Blue to Gold law enforcement training, bring it to the roadside chat from Joplin, Missouri. Got a question from an officer in Florida. He basically wants me to clarify protective sweeps and murder scenes. Okay, so the officer says, you know, he was watching one of my videos regarding protective sweeps, I mentioned the case called Mincy versus Arizona. And I'll explain in a second, where I talked about there's, you know, the Supreme Court ruled that there is no murder scene exception to the search warrant requirement. Okay. And then, you know, so he's talking about look, you know, however, if response reporting shooting in a driveway of a residence, wouldn't we have exigent circumstances, to conduct a warrantless sweep of the residence for possibly other injured parties to see if the perpetrator is still on scene, you know, and so forth. Right. Also, the officer says, you know, we also, you know, follow the trajectory of the bullet to see if other people been injured, you know, across the street, maybe in the back, you know, the other houses on the other street and so forth. And, and to make sure that nobody was hit similar to a public safety statement, you know, hey, where did you shoot? How many rounds? Did you fire? That type of thing? I'm looking at my computer, by the way. So any clarification would help? Look, let's let's do this. This is, uh, this is great. This is a great question. It's a great follow up question. Let's make sure that if there's some confusion about what I'm saying, you're like, man, you know, that doesn't really sound right. You know, please, I want you to reach out to me, because in my brain, it all makes sense. But when I make these quick videos on the road, I could say something that may not be. I mean, it makes sense. So let's first talk about Mincy versus Arizona. Look, the general rule there is that once police secure the scene, and they're looking for other victims, and they don't find anybody looking for that perpetrator, that you can't, you can't just stay in people's homes, process a crime scene, you know, and then use that evidence against somebody who has a privacy interest in the home. And in the Mincy case, the cops are actually in the house for four days, four days processing that crime scene, and no warrant and no consent. So that's the problem. All right. And they, you know, they recover, like almost 300 pieces of evidence, and so all that was suppressed. And that's not the way we do it. So instead, when we have a crime scene, we go to a murder scene, right, like a shooting and so forth. What we're gonna do is we're gonna arrive on scene, and we're going to, you know, potentially enter the home if you believe that more victims, or the perpetrator can be in the home. So what the officer is saying is absolutely correct, right. You know, that's what they're doing. And that is absolutely permissible. Mincy does not prevent that, because menses only about processing crime scenes. It's not about protective sweeps, that would fall under other court cases. Marilyn versus buoy US Supreme Court. I also think a case called Ryberg. Versus Huff would also kind of cover the public safety aspect. It's it's not directly on point, but it does talk about how when officers, you know, reasonably believe that they're about to be attacked, you know, they can enter homes and so forth. And I think that would apply for potential perpetrators. But look, the vast majority of courts, if not all, courts, are going to let cops go in there and look for perpetrators and more victims...

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Hey guys, Anthony Bandiero Here attorney, Senior Legal instructor for Blue to gold law enforcement training, bringing to the roadside chat from Joplin, Missouri. What a great place, by the way, my first time here, and it won't be my last. All right. So I have a question for Nasir. He actually doesn't say what state he's from. And his email addresses personal email address, but that's okay. And he wants clarification on detaining someone who committed a crime. But the victim doesn't want to press any charges. And then they want to know about, you know, can we still detain him, identify him, try to find out what his story is, and so forth. So this situation is this, they responded to a suspicious person called, of unknown subject, knocking on a door that doesn't belong there. As he left, he broke a vase that was on the patio, you know, that can just imagine this guy just like, something's wrong with him. He just like, smacks his face and it just breaks, right? They can they contacted the homeowner, right? And she says, Look, I don't want anything done, right? I'm not going to be a victim here, and just let it go. I want nothing to do with it. So they then leave? Well, they then see him walking down the street. And they considering a consensual contact. You know, since the victim doesn't want anything done, but the officer is asking, you know, let's say he doesn't want to engage in a consensual contact, can we actually detain him? Right? And investigate? And here's my answer. I think the answer is no, I don't really have a case on this. I've never seen a case on this. But I think jelly answer's no. Because look, if you look at the tensions, what are they for, they're supposed to be for conforming or dispelling whether criminal activity is afoot, right? criminal activities ongoing. So we basically have no victim no crime. That's kind of the way I'm looking at this right? You have a person who's saying, I don't want to make this a criminal issue, right? This is gonna be a wash for me. So you don't have that? You. You also don't have. And again, I'm spitballing here because there could be a case out there that that says, yeah, actually, we can still contact him and so forth. I'll tell you one of potential what I think we could do but wait for it. And then also, we don't have probable cause, either, because we have no, you know, we don't have enough evidence, because we have no victim that doesn't want to make this a crime. We don't have evidence that the person at this point has engaged as committed a crime, because again, you got this no victim, no crime kind of idea. So I would say no, I would not detain this person; if they don't want to talk, they can keep on walking. Here's the caveat. If the officer has facts or circumstances that lead him or her to reasonably believe that this person will commit a future crime, right, that this person, you know, maybe we saw him going up to other people's houses and knocking on the door. I'm definitely good on that point. I'm definitely good with a detention at that point. Because it looks like he's going from house to house and he could be breaking more stuff in plus, what is he really up to? ...

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Hey guys, Anthony Bandiero Here attorney, Senior Legal instructor bringing a roadside chat from an officer in Texas. Now, this officer says, you know, ask basically can we automatically pat down suspected gang members? Right? And to give you a little context here, the officer is talking about, you know, attending some outlaw motorcycle gang training, and, you know, get a lot of bad deals in the area. And then instructors basically saying, hey, look, if you are dealing with a one percenter, right? Michigan versus long, which is a US Supreme Court case, about first can vehicles allows you to essentially, you know, conducted frisk of that motorcycle for for weapons. The officer will first ask, though, this is what they teach, they'll ask for consent to search the motorcycle, if they say no, then they get them off the bike. And they search it anyway. Because of their because they're, it's known that gang members can easily access the saddlebag these game members can access to settle back and potentially grab a weapon. Now, the question is, is does Michigan versus long really hold that that suspect a gang members, you know, essentially can be automatically patted down just with that fact alone. And certainly, Michigan versus long doesn't it's not that fact pattern that's that case involved a drunk driver who crashed into a ditch and the officer saw him trying to go back to the car, it was a knife in the in the mat pocket in the door, if the door is open, you got you know, long back and another partner looked for sees the knife and look for more weapons in the immediate area, and found narcotics in the center console and the Supreme Court upheld it because the logic was, hey, look, he was trying to go back to the vehicle. It's, you know, it's a fluid situation, he's intoxicated, there was only one weapon in there, that could potentially be another weapon in there. And that frisk of the vehicles upheld, but it certainly didn't talk about anything about gang members. Now. All I can tell you is what I teach, right? I don't teach automatics like, you know, automatic searches, you know, for my cops. There's really no automatics out there. There's no free lunch when it comes to the Fourth Amendment, you're going to have to work for it a little bit, you're gonna have to go to court and explain that simply having a 1% patch. You know, that's one factor. It's a very important factor and, and but what else do you got there? I mean, you know, we're gonna have to have something more. And usually there's going to be so that's the good news. Here are some cases that kind of, you know, illustrate what I'm talking about, right. Here's a case out of Kansas, a case called State vs. Goldston. 2009. Now it says here at the time that the officer conducted the pat-down, he knew the following facts about the suspect. He was in a database as a documented gang member. He was with a known gang member who was on supervised release from prison and had been involved in prior stop involving drugs within the last two weeks. He had just come from a city known for drug activity, and were several arrests and or area of town. Actually, I think, I'm sorry, it's not a city. It was a gas station. He just came from a gas station where several rest of them made recently for drug activities and so forth. The officer also articulated he knew that drug dealers that involved in gangs often had weapons to protect the drugs and the money. Right. They're self help, right? They're like their own little police department. And considering all these facts, the court upheld, but do you see what's going on there? It's not just saying Your Honor. The person is a one percenter therefore, I conducted a vehicle suite, you know, or pat down. We need something more than that in mind book, but you're gonna have it usually...