Case Explained: United States of America v. Malachi Patton Handley

Court: United States Court of Appeals for the Eighth Circuit Filed: 2026-08-11 The Eighth Circuit affirmed the district court’s denial of Malachi Handley’s motion to suppress evidence found in his vehicle, holding that while a drug dog’s physical intrusion into an open vehicle window constitutes a Fourth Amendment search under *United States v. Jones* and *Florida v. Jardines*, the exclusionary rule does not apply because law enforcement officers acted in objectively reasonable reliance on binding Eighth Circuit precedent (*United States v. Lyons*) existing at the time of the stop. The court applied the standard that warrantless searches are per se unreasonable unless an exception applies, noting that a dog’s intrusion into a vehicle is a physical trespass for information gathering that qualifies as a search. However, the court determined that under *Davis v. United States*, the exclusionary rule serves only to deter deliberate, reckless, or grossly negligent police conduct and does not apply when officers rely on binding appellate precedent until it is authoritatively overruled. The court found that although *Jones* and *Jardines* cast doubt on the specific holding in *Lyons* regarding instinctive canine actions, neither Supreme Court decision explicitly overruled *Lyons*, and a reasonable officer could not have anticipated that the precedent was invalid. Consequently, the officers’ reliance on *Lyons* to conclude the dog’s unprompted entry did not violate the Fourth Amendment was objectively reasonable, precluding the application of the exclusionary rule despite the technical constitutional violation. As a result, the evidence seized (a firearm and marijuana) remains admissible for Handley’s criminal prosecution, and his conviction for being a felon in possession of a firearm stands; no further relief is granted regarding the suppression motion. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.