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Usav.Willie Lee Cooks

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.18-10080
DecidedApril 3, 2019
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalCriminal ProcedureFourth AmendmentSearch and SeizureWarrantless SearchEvidenceReversal
Case Summary

During a four-hour standoff at Willie Lee Cooks’s home, officers believed that other occupants might be unable to leave and heard sounds suggesting that Cooks was working in a hole in the floor. After the standoff ended, officers entered, pried up a screwed-down plywood cover, and found firearms in the crawlspace. Cooks pleaded guilty to firearm offenses but preserved his challenge to the search. The Eleventh Circuit held that the warrantless crawlspace search was lawful under the exigent-circumstances doctrine. The officers had probable cause to believe that the hole could contain additional hostages, and the Fourth Amendment inquiry depended on what they reasonably knew at the time rather than on hindsight. The majority therefore reversed the district court’s suppression ruling. A dissent argued that the officers had only speculation, not probable cause, that a hostage was in the crawlspace, and that removing the cover exceeded any protective sweep. The published opinion is significant for applying emergency-aid principles to an enclosed space inside a home and for drawing a sharp majority-dissent line over the facts needed to justify a warrantless search.

Opinion

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