Luis Miguel Sierra-Ayala v. United States
FourthAmendment CriminalProcedure Privacy JusticiabilityDoctri
Should evidence obtained during an illegal police seizure be suppressed where the rights-violating officer testifies that the person in his custody consensually turned over contraband?
QUESTION PRESENTED A police officer cannot touch a person’s body or possessions without consent or legally sufficient basis. Likewise, an officer cannot force himself upon a person’s private personal space, impeding their freedom to leave without justification. Agreeing with these bedrock privacy concerns, the First Circuit determined that when a police raid squad descended upon a residential street and accosted Petitioner Luis SierraAyala, his Fourth Amendment rights were violated. When the squad, directed by Sergeant Lépez-Maysonet, burst upon Petitioner and others on a Sunday morning, none of the sergeant’s excuses for seizing Petitioner sufficed. Neither the flight of others, nor the idea of a high-crime area, nor the use of a fanny pack gave rise to reasonable suspicion. Nevertheless, while Lépez-Maysonet halted and controlled Petitioner without cause or consent, the First Circuit conceived of a separate basis to deny Petitioner’s request to suppress contraband found during the illegal encounter. The First Circuit concluded that Petitioner — despite his illegal and non-consensual placement under the sergeant’s official control — consensually opened up the accessory bag he wore to reveal drugs inside. The bag opening act immediately followed the illegal seizure. The question presented is: Should evidence obtained during an illegal police seizure be suppressed where the rights-violating officer testifies that the person in his custody consensually turned over contraband? i PARTIES Luis Miguel Sierra Ayala, petitioner on review, was the defendant-appellant below. The United States of America, respondent on review, was the plaintiff-appellant below.