United States v. Santana

Facts

Undercover officer was attempting to make a heroin buy from McCafferty.  McCafferty drove officer to Santana’s residence, McCafferty went inside, then returned with heroin.  McCafferty was placed under arrest and other officers went to Santana’s home, finding her standing in the doorway.  As the officers approached, Santana went inside and officers proceeded inside, discovering narcotics and the marked bills from the transaction.

Procedural History

Trial court granted Santana’s motion to suppress and the Court of Appeals affirmed.

Issue(s)

Did the lower courts err in suppressing the evidence retrieved from the search when Santana was noticed standing in the doorway?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that it is clear that Santana was in a public place and not where she had an expectation of privacy.  The act of retreating into the house could not thwart an otherwise proper arrest.  A suspect may not defeat arrest which has been set in motion in a public place by the expedient of escaping into a private place.

Judgment/Outcome

The Court reversed and remanded the judgment of the lower courts.