Haldorson, a fireworks enthusiast and a drug dealer, was arrested on his way to a second controlled buy. Along with drugs, officers found three pipe bombs in his car. He was charged with several counts related to drugs, explosives, and a firearm. Haldorson unsuccessfully moved to suppress evidence based on Fourth Amendment violations and was convicted on four counts a seven-count indictment. Haldorson was sentenced to 192 months of imprisonment.
The Seventh Circuit affirmed, upholding the denial of the motions to suppress. The court held that probable cause that was based on a “controlled buy” three weeks earlier supported the arrest. Furthermore, the court found that emergency exigent circumstances existed for the warrantless search of his bedroom. There was a legitimate concern that other homemade explosive devices were in Haldorson’s bedroom and were dangerous to others.
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