U.S. v. Correa

In prosecution on drug and firearm charges, Dist. Ct. did not err in denying defendants’ motion to suppress seizure of drugs and firearms from one defendant’s condominium, where record showed that: (1) one defendant was lawfully stopped on traffic violation after said defendant had been observed by police making alleged drug transaction; (2) during search of car, officer found bag containing 4 garage door openers, 3 sets of keys and 4 cell phones; (3) officers arrested said defendant, took one garage door opener and began punching opener at various homes until garage door opened at condominium complex; and (4) after officer used key fob to gain access to lobby of condominium complex and then used mailbox key to identify defendant’s unit, police obtained consent of defendant to search his unit. While police use of garage door opener constituted search for 4^th Amendment purposes, no violation occurred, where it opened garage shared by many residents of complex. Moreover, police use of key fob and mailbox key to identify defendant's unit was consistent with 4^th Amendment.