News Roundup

Additional information came to light last week in the case against Luigi Mangione, the 27-year-old man accused of murdering UnitedHealthcare CEO Brian Thompson, during a key pretrial hearing on a motion to suppress. At issue was whether the search of Mangione’s backpack in an Altoona, PA, McDonald’s five days after the Manhattan shooting was lawful where officers had not obtained a warrant. The defense also argued that certain statements should be suppressed because officers did not Mirandize Mangione until 20 minutes had passed. The question of whether it was lawful to search Mangione’s backpack without a warrant evokes the Fourth Circuit case of United States v. Davis, which Shea blogged about here. In Davis, the Fourth Circuitheld that the search of the defendant’s backpack was unlawful where the defendant was lying handcuffed on his stomach and thus could not plausibly reach for the backpack at the time officers searched it. This was a notable expansion of the Arizona v. Gant case beyond the context of searches of motor vehicles. However, the analysis is highly fact-dependent, as Shea’s comparison to other cases in the blog demonstrates. Small distinctions involving the relative freedom of the defendant and the potential to access the bag can make a big difference. Furthermore, investigators in the Mangione case claimed the risk that the bag contained a bomb justified the warrantless search. Additional questions surrounding inventory searches, inevitable discovery, and Pennsylvania law on search incident to arrest may come into play in the ultimate ruling. The judge indicated [...]