Case Explained: United States of America v. Amir Kalomo Mulamba

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-12 The eighth-circuit affirmed the district court’s denial of Amir Mulamba’s motion to suppress evidence obtained from his cell phone, holding that law enforcement officers had probable cause and exigent circumstances to seize the device without a warrant and that the subsequent search warrant was valid. The court applied the Fourth Amendment standard for warrantless seizures, determining that officers reasonably believed Mulamba was attempting to solicit a minor for a commercial sex act in violation of 18 U.S.C. §§ 1591 and 1594 based on the totality of circumstances, including eyewitness testimony from the victim’s mother and the victim herself, corroboration of vehicle details and social media identities, and Mulamba’s own furtive gestures and admission that he was deleting messages related to the victim. The court found these facts created an exigency because a reasonable officer would believe evidence was imminently being destroyed. Regarding the search warrant, the court applied the *Franks v. Delaware* standard, rejecting Mulamba’s challenge to the affidavit supporting the warrant. The court held that even if the alleged omissions and misrepresentations in the affidavit were corrected—specifically regarding the timing of Mulamba’s consent, a statement about nude photos, and the duration of retrieving his phone—the remaining unchallenged facts still established probable cause to believe the phone contained evidence of attempted sex trafficking. As a result, the conviction for production of child pornography under 18 U.S.C. § 2251(a) stands, and the case is remanded with no further proceedings required regarding the suppression motion. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.