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United States v. Kelly
United States Court of Appeals for the Fourth Circuit
592 F.3d 586 (2010)
Facts
Federal and local agents investigated David Kelly (defendant) for drug-dealing operations for a year and obtained an arrest warrant for Kelly and search warrants for his house and commercial property. Although police knew that Kelly drove multiple cars, the warrant did not authorize a search of the cars. After police executed the warrant at Kelly’s house, arrested Kelly, and questioned him in a patrol car, they had a drug-sniffing dog check the car that officers observed Kelly driving the previous day. The dog alerted to the car’s passenger compartment, but police did not find any drugs there. Police searched the entire car and found cocaine and ecstasy in the trunk. Kelly moved to suppress the drugs, arguing that police improperly searched the car while he had no access to it and that the search of the entire car was too broad. The district court denied Kelly’s motion to suppress, a jury convicted Kelly of various drug charges, and Kelly was sentenced to life in prison. Kelly appealed the denial of his motion to suppress.
Rule of Law
Issue
Holding and Reasoning (Wilkinson, J.)
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