United States v. Stokes, No. 12-2843 (2d Cir. 2013)
Annotate this CaseDefendant was convicted of possession of firearms by a convicted felon and possession of a machinegun by any person. On appeal, defendant challenged the district court's denial of his motion to suppress the firearms, which were discovered after a warrantless entry into defendant's motel room, based on the inevitable discovery doctrine. The court concluded that the district court erred in determining that the record supported a finding that the evidence at issue would inevitably have been discovered. The district court's inevitable discovery analysis was erroneous in several respects and the court held that the government failed to prove by a preponderance of the evidence that the guns and ammunition would inevitably be discovered. Accordingly, the court vacated defendant's conviction, reversed the denial of the suppression motion, and remanded for further proceedings.
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