State v. Watts
Annotate this CaseAlan Watts was convicted of possession with the intent to deliver, drug stamp tax violations, and possession of drug paraphernalia. Watts appealed, contending that the district court erred in denying his motion to suppress evidence obtained from searching his apartment. The Supreme Court affirmed Watts' convictions and sentence, holding that although the initial warrantless sweep of Watts' apartment was unlawful due to a lack of exigent circumstances, the district court did not err in denying Watts' motion to suppress because (1) the officers later procured a warrant to conduct a full search of the apartment, (2) the evidence in question was located during that search, and (3) the State demonstrated that the warrant would have been sought and granted even without the information from the earlier improper sweep.
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