U.S. v. Howard

Defendant, who sold drugs while also acting a confidential informant for federal law enforcement, was found guilty of three drug crimes. On appeal, he argued that the district court improperly quashed a witness subpoena that would have allowed defendant to present evidence that law enforcement authorized his conduct, that the district court erred when it denied defendant’s motion to suppress evidence found during a warrantless search of his home and cell phone, and that the evidence was not sufficient to convict him. The Seventh Circuit affirmed, finding that the district court did not abuse its discretion in quashing the witness subpoena, that the evidence from defendant’s home and cell phone would have been inevitably discovered through lawful means, and that a rational trier of fact could conclude beyond a reasonable doubt that defendant was guilty of the crimes for which he was convicted. (SCUDDER and JACKSON-AKIWUMI, concurring)