United States v. Curlie Quarterman

Citation: 877 F.3d 794Docket: 16-4519

Court: Court of Appeals for the Eighth Circuit; December 12, 2017; Federal Appellate Court

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Police officers entered Curlie Marque Quarterman's apartment without a warrant following a 911 call from Carol Bak, who reported a heated altercation with Quarterman, during which he displayed a firearm. The officers were concerned for the safety of Bak's daughter, Christina, who was still inside the apartment. Upon arrival, they observed a chaotic scene and heard voices. After knocking, Christina answered, and the officers noticed Quarterman moving quickly on the couch, which raised their suspicions. They entered the apartment to ensure safety, during which they saw a handgun on Quarterman's waist as he attempted to stand. The officers ordered Quarterman to comply and seized the firearm, which was later discovered to be stolen. Quarterman was subsequently arrested and moved to suppress the gun and related evidence, arguing that the warrantless entry violated the Fourth Amendment. The district court granted the motion, determining that there were no exigent circumstances or probable cause for the entry. The government appealed, and this court, having jurisdiction under 18 U.S.C. 3731, reversed the district court's decision and remanded the case for further proceedings, reviewing the exigent circumstances de novo.

The Fourth Amendment's standard is reasonableness, which requires evaluating the totality of officers' actions. Warrantless searches in homes are generally considered "presumptively unreasonable," but exceptions exist if exigent circumstances arise, such as the need to assist someone seriously injured or threatened. Officers may enter without a warrant if they have an objectively reasonable basis to believe immediate aid is needed or if there's a threat to officer safety. In this case, officers had credible information about a potentially dangerous situation involving Quarterman, who was armed and had been in a heated argument. When Christina Bak opened the door, Quarterman's quick movements raised the officers' concerns, prompting them to enter the residence to ensure safety. The situation mirrored a previous court decision where officers, fearing for their safety in a similar scenario, were justified in entering without a warrant. The court concluded that the officers acted reasonably given the immediate threat and the circumstances they faced.

Quarterman contends that the level of danger in his situation was not as severe as in the case of Roberts, yet the court maintains that exigent circumstances arise when officers reasonably perceive a threat from a firearm or an armed individual. Precedents such as *United States v. Henderson* and *Uscanga-Ramirez* illustrate that the presence of a gun can justify warrantless entry into a residence to avert potential harm. While acknowledging that the mere presence of a weapon does not automatically establish exigent circumstances, the court found that officers acted reasonably given Quarterman’s conduct—carrying a gun while evicting his girlfriend and confronting her mother early in the morning. Despite Quarterman's argument that there was no domestic disturbance, the officers had a reasonable basis to believe an ongoing dispute was occurring, as indicated by his actions. The court emphasized that the combination of Quarterman being armed and the volatile nature of domestic disturbances validated the officers' belief in a potential threat. Upon lawful entry, the exigent circumstances permitted the officers to order Quarterman to comply and allowed for a limited search to secure the weapon, aligned with established legal principles regarding warrantless searches in exigent situations.

The Eighth Circuit held that the officers’ entry into Burke’s home was lawful under emergency aid or community caretaking justifications, making their brief detention of Burke legal. Although Quarterman denied possessing a gun, the officers had reasonable grounds to disbelieve him based on information from Carol Bak, who indicated that Quarterman had a gun on his hip. The officers’ observations of Quarterman suggested he might be armed, and upon seeing the gun, they were justified in its temporary seizure. 

The court clarified that while exigent circumstances can substitute for a warrant, probable cause is generally required before conducting a search. However, this requirement does not apply uniformly across all exigent circumstances. Various scenarios, such as providing urgent aid or preventing evidence destruction, allow for warrantless entry without probable cause. 

The court emphasized that an objectively reasonable belief in the need to protect life or prevent serious injury is sufficient justification for actions that would otherwise be illegal. The district court's decision to suppress the gun and related evidence was deemed erroneous, leading to the reversal of the judgment and remand for further proceedings consistent with this opinion.