United States of America v. Joan Manuel Estadella

Miami, Florida, criminal defense lawyer represented the Defendant charged with felony possession of a firearm and possession with intent to distribute meth.

An indictment in the Southern District of Florida charged
Estadella with (1) possessing a Taurus 9mm pistol with serial
number TLZ57339 and its ammunition as a convicted felon
between November 28, 2020, and December 1, 2020, in violation
of 18 U.S.C. §§ 922(g)(1) and 924(a)(2) (Count 1); (2) possessing a
Springfield Armory .380 caliber pistol with serial number
CC121963 and its ammunition as a convicted felon between
November 30, 2020, and December 1, 2020, in violation of 18
U.S.C. §§ 922(g)(1) and 924(a)(2) (Count 2); (3) possessing
methamphetamine with intent to distribute, in violation of 21
U.S.C. § 841(a)(1) (Count 3); and (4) possessing a firearm in
furtherance of a drug trafficking crime, in violation of 18 U.S.C.
§ 924(c)(1)(A)(i) (Count 4). Estadella pled not guilty and proceeded
to trial.

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16 Opinion of the Court 23-11061
deed was recorded. As of November 30, 2020, Dianellys thus
owned the West 17th property and had actual authority to consent
to the search.
As to both Soriano and Dianellys’s consent, the district court
found that their consent to search the property was unlimited.
Even assuming their consent could not extend to parts of the
house, such as Estadella’s locked office, the district court noted the
detectives obtained a search warrant before entering the locked
office inside the property.
C. The Fourth Amendment and Consent Searches
The Fourth Amendment protects “[t]he right of the people
to be secure . . . against unreasonable searches and seizures.” U.S.
Const. amend. IV. “As the text makes clear, ‘the ultimate
touchstone of the Fourth Amendment is reasonableness.’” United
States v. Harden, 104 F.4th 830, 833 (11th Cir. 2024) (quoting Riley v.
California, 573 U.S. 373, 381 (2014)). The Fourth Amendment
evinces a “strong preference” that searches be performed pursuant
to a warrant, and warrantless searches of a home are presumptively
unreasonable. United States v. Grushko, 50 F.4th 1, 10–11 (11th Cir.
2022) (citing Payton v. New York, 445 U.S. 573, 586 (1980)).
While the “Fourth Amendment generally prohibits the
warrantless entry of a person’s home[,] . . . [t]he prohibition does
not apply . . . to situations in which voluntary consent has been
obtained, either from the individual whose property is
searched . . . or from a third party who possesses common
authority over the premises.” Illinois v. Rodriguez, 497 U.S. 177, 181, (1990) (citations omitted); see also Fernandez v. California, 571 U.S.
292, 298 (2014) (providing that law enforcement may carry out a
warrantless search when they obtain consent from the sole owner
or occupant of a home).
A consent to search “must be voluntary—not the ‘product
of duress or coercion.’” Dukes v. Sheriff of Levy Cnty., 155 F.4th 1291,
1297 (11th Cir. 2025) (quoting Schneckloth v. Bustamonte, 412 U.S.
218, 227 (1973)). The permissible reach of a consent search is
limited by the scope of the given consent, as understood by a
reasonable person. Florida v. Jimeno, 500 U.S. 248, 251 (1991).

The Defendant was found guilt.

Affirmed