Chatrie v United States Supreme Court Geofence Warrant 2026
From the United States Supreme Court Geofencing to Catch a Bank Robber Chatrie v. United States, slip opinion No. 25-112 In another case involving technology which was beyond science fiction when the Bill of Rights and specifically the Fourth Amendment was adopted, the United States Supreme Court considered the constitutional implications of law enforcement using geofencing during investigations. In Chatrie, the Court began with a description of geofencing and its use for investigations and the warrant that was obtained by investigators in this case. The Court noted that certain apps have the ability to track locations of devices using these [...]
ICE Immigration Detainers:
ICE Immigration Detainers: Legal Requirements and Liability for Local Law Enforcement The increase of immigration enforcement has led to questions regarding the enforcement of immigration detainers by city and county jails. This article will discuss various court precedents related to local enforcement of immigration detainers. To be clear, detainers refer to requests by Immigration and Customs Enforcement (ICE) to continue to hold a person in custody (jail) after the person is eligible to be released, for example, after posting bond for a state criminal charge. Galarza v. Szalczyk – Third Circuit Court of Appeals (2014) In Galarza v. Szalczyk[i], the Third [...]
THE ART OF THE INTERNAL INTERVIEW: CONDUCTING EFFECTIVE OFFICER INTERVIEWS IN LAW ENFORCEMENT INVESTIGATIONS
Introduction Of all the components that comprise a law enforcement internal investigation, none carries greater weight than the officer interview. When reviewing completed investigations, commanders and oversight bodies almost invariably ask the same question first: What did the officer say? That answer, or its absence, can determine administrative outcomes, shape civil liability exposure, and define whether a department can demonstrate accountability to the community it serves. For these reasons, internal affairs investigators must approach officer interviews not as a procedural formality, but as a discipline worthy of rigorous preparation and skillful execution. This article addresses the legal framework governing officer [...]
TENTH CIRCUIT CONSIDERS REASONABLENESS OF DEADLY FORCE FOR SHOOTING MAN THAT DISOBEYED COMMANDS NOT TO TOUCH WEAPON
On May 28, 2025, the Tenth Circuit Court of Appeals decided Cruz v. City of Deming[i], which serves as an excellent review of the law related to the use of deadly force under the Fourth Amendment. The relevant facts of Cruz, taken directly from the case, are as follows: On February 3, 2021, a motorist driving on Interstate 10 near Deming, New Mexico called 911 to report a man, wearing a gray sweater and a hat, standing in the median "shooting" a "big gun" at westbound traffic. The motorist indicated she was unclear if the gun was real. Officers from [...]
FOURTH CIRCUIT FINDS NO CONSTITUTION VIOLATION FOR OFFICERS THAT SHOT MAN THAT DISOBEYED VERBAL COMMANDS, MADE FURTIVE MOVEMENT AFTER VEHICLE PURSUIT
On June 3, 2025, the Fourth Circuit Court of Appeals decided Benton v. Layton[i], which serves as an excellent review of the law related to the use of deadly force under the Fourth Amendment. The relevant facts of Benton, taken directly from the case, are as follows: At 4:35 a.m. on January 9, 2021, Defendants were in a marked police vehicle in a highway median, with Layton in the driver's seat. Hill passed Defendants on the highway, Dashcam at 1:42,1 and Layton U-turned from their position and drove up the three-lane highway. Bone confirmed with Layton that they were moving [...]
EIGHTH CIRCUIT DISCUSSES PROLONGED TRAFFIC STOPS AND THE SEARCH OF PASSENGER’S PURSE
On May 28, 2025, the Eighth Circuit Court of Appeals decided the United States v. Agena[i], which serves as an excellent review of the law related to prolonged traffic stops and the searching of a passenger’s bag. The relevant facts of Agena, taken directly from the case, are as follows: This case began with a traffic stop near Waverly, Nebraska, in June 2022. At around 2:00 a.m., Deputy Jason Schnieder and Deputy Taylor Castaneda of the Lancaster County Sheriff's Office stopped a vehicle for a traffic violation because the driver's side taillight was not illuminated. See Neb. Rev. Stat. § 60-6,219(3), [...]