United States v. Edwards

Carbeania Grimes called the police and told them that Troy Edwards (defendant), her boyfriend, had assaulted her. When the police arrived, they saw Edwards driving a car outside of the home and arrested him. The car did not belong to Edwards, but officers found several papers in the car that belonged to Edwards. The officers neglected to inventory the papers. Officers also found a black bag inside the car that contained crack cocaine. Edwards was charged with possession of cocaine with intent to distribute. Edwards claimed that the black bag was not his, and there was initially no evidence tending to prove that it was. After the bag was introduced into evidence at trial, the bag was taken to the U.S. Attorney’s office, which was a violation of local court rules. That night, the prosecution (plaintiff) examined the bag and removed a cardboard bottom from the bag. Under the cardboard, the prosecutor allegedly found a crumpled bail receipt with Edwards’s name on it. The receipt had not been discovered during the police’s initial search of the bag. The district court introduced the receipt into evidence over Edwards’s objection. Edwards was convicted, and he appealed. The United States Court of Appeals for the Ninth Circuit reversed on grounds unrelated to the admission of the receipt. At Edwards’s second trial, Edwards again filed a motion to exclude the receipt. The district court denied the motion, and Edwards was convicted. He appealed.