The United States Court of Appeals for the Seventh Circuit recently decided United States v. Maxwell, a case that challenges the scope of the Exigent Circumstances doctrine during a 90 second, warrantless search at an Illinois apartment complex.1 After gunshots led to an urgent 911 call from the apartment complex, police, relying on the Emergency Aid Doctrine, made immediate entry into Tyrone Maxwell’s apartment; Unit 7.
In August 2019 in Springfield, Illinois, two individuals, who were non-residents of an apartment complex, tried to gain access to the building, specifically targeting Apartment Unit 7. The two men successfully secured their entry by deceiving the residents of a neighboring unit to buzz them in, claiming they were trying to contact someone in Apartment 7. Moments after they were buzzed in, the sound of gunshots echoed through the hallways of the complex, prompting a swift and concerned response from the residents, who dialed 9-1-1. The responding officers arrived to find a scene telling of recent gunfire. They were confronted with physical evidence that suggested a serious incident had occurred: the door to Apartment 7 covered in bullet holes, the staircase was scattered with shell casings, and an empty gun holster lay nearby.
Faced with this evidence, the officers had to consider the possibility that someone inside the Apartment might need urgent medical attention. They promptly called for an ambulance and made multiple attempts to contact the apartment’s occupants; knocking and announcing their presence but received no response.
After their attempts to manually gain entry were unsuccessful, the officers considered the potential severity of the situation and decided to use a sledgehammer to enter through the deadbolted door. The sledgehammer fractured the door, splintered the doorjamb, and the officers successfully broke open the deadbolt after 10 minutes. After breaching the door, the officers were overwhelmed with the strong odor of marijuana, soon confirmed after the officers saw the drugs in plain view. Sergeant Barksdale, taking the lead in the search, entered the bedroom. There, a sizeable closet was inspected, revealing a massive stash of marijuana. In the living room, a similar search of another large closet led to the discovery of a rifle. The search, in total, lasted approximately 90 seconds—a brief but thorough sweep in line with the exigency of the situation.
Maxwell’s arrival post-search marked a turning point, as it was determined that the apartment belonged to him. This new information led to the officers obtaining a search warrant for the Unit. The detailed search that ensued uncovered two firearms, a large quantity of marijuana exceeding 10 pounds, and $75,000 in cash.
The warrantless search of Unit 7 led to the defendant’s 3-count indictment; possession of marijuana with intent to distribute, possession of firearms in furtherance of a drug trafficking crime, and possession of firearms as a felon. Maxwell moved to suppress the evidence seized during the searches, but the district court denied the motion and the defendant entered a conditional guilty plea on the drug-related counts.
After the denial of the defendant’s motion to suppress, Maxwell appealed to the Seventh Circuit, challenging the constitutionality of the search under the Fourth Amendment. On appeal, the Seventh Circuit considered, ‘whether the police had a reasonable basis to believe that a person in Maxwell’s apartment was seriously injured, thus justifying their warrantless entry and search under the Fourth Amendment.’
The defendant’s appeal focused on three primary arguments, which he contended demonstrated the unreasonableness of the officers’ actions in this situation. First, he challenged the officers’ basis for believing that an individual in his apartment required emergency aid. The Seventh Circuit found that when the officers entered the apartment, they were guided by an objectively reasonable belief that someone inside might be injured. This belief was central to justifying the warrantless search.
Next, Maxwell questioned the reasonableness of using a sledgehammer to enter his apartment. The Court focused on the manner of the officer’s entry, finding that the method of entry by the police, though forceful, did not result in excessive or unnecessary damage to Apartment 7; a crucial point in evaluating the reasonableness of their actions.
Lastly, the defendant argued that any exigent circumstances either ended upon the officers’ initial entry or the officers should have confined their search to the immediate vicinity of the door. The Court explained that the scope of the search was accurately confined to areas where an injured person could reasonably be expected to be found, demonstrating a targeted approach rather than a broad sweep.
The Seventh Circuit affirmed the denial of the defendant’s motion to suppress the evidence obtained during the warrantless search of his apartment, concluding that the officers’ actions were deemed lawful and justified given the circumstances.
United States v. Maxwell encapsulates the complexities of the Exigent Circumstances Doctrine and the scope of reasonable searches under the Fourth Amendment. The details of the case underline the critical nature of quick, yet calculated decision-making in the face of potential life-threatening scenarios all while upholding the constitutional rights afforded to all parties involved. The Seventh Circuit’s decision highlights the importance of objective reasoning in determining exigency, the permissible scope of force in entry, and the importance of tailoring a search under the Emergency Aid Exception to potential victims and vicinities where a victim would likely be located.
- United States v. Maxwell, No. 22-2135 (7th Cir. 2023). ↩︎