United States v. Coles et al.: Limits on Administrative Warrant Use and the Categorical Crime-of-Violence Rule

Introduction

This commentary examines the Third Circuit’s April 7, 2025 decision in United States v. Kevin Coles, Nicholas Preddy, and Johnnie Jenkins-Armstrong, a consolidated appeal arising from a drug-trafficking conspiracy and a triple homicide orchestrated to retaliate against an informant. The defendants challenged their convictions and sentences on multiple fronts, including:

The validity and scope of administrative and electronic surveillance warrants;
The categorization of Hobbs Act robbery as a “crime of violence” under 18 U.S.C. § 924(c);
Evidentiary rulings on impeachment and hearsay; and
The reasonableness of upward departures and life sentences.

For ease of reference, this analysis will proceed through a concise summary of the court’s decision, a detailed examination of the precedents and legal reasoning invoked, a look at the likely impact on future prosecutions, a plain-English explanation of technical doctrines, and concluding observations.

Summary of the Judgment

The Third Circuit affirmed in full the convictions and sentences of all three appellants. Key holdings include:

No Fourth Amendment violation in Maryland police’s execution of a New York administrative parole warrant—the Abel bad-faith exception to the objective standard was not triggered.
Electronic surveillance orders under Pennsylvania law did not trigger suppression absent a federal constitutional violation—and the good-faith exception applied to cell-site data warrants pre-Carpenter.
Hobbs Act robbery remains a categorical crime of violence under § 924(c)’s elements clause, despite the Taylor limitation on attempted robbery.
No abuse of discretion in permitting the government to impeach its own witness under Rule 607, nor in excluding a non-testimonial hearsay statement under the residual exception.
Upward departure under U.S.S.G. § 5K2.21 and life sentences were procedurally and substantively reasonable given the gravity of the uncharged triple homicide and witness-retaliation conduct.

Analysis

1. Precedents Cited

Abel v. United States (362 U.S. 217 (1960)): established that administrative warrants used for criminal evidence must be issued in bad faith to violate the Fourth Amendment.
Leon (468 U.S. 897 (1984)): recognized the “good-faith exception” to the exclusionary rule for objectively reasonable warrant reliance.
Carpenter v. United States (585 U.S. 296 (2018)): held that cell-site location information is subject to Fourth Amendment protection—but did not apply retroactively to pre-Carpenter warrants.
Franks v. Delaware (438 U.S. 154 (1978)): permits suppression where an affidavit contains deliberate falsehoods or reckless omissions material to probable cause.
United States v. Taylor (596 U.S. 845 (2022)): clarified that attempt liability under the Hobbs Act is not categorically a “crime of violence.”
Stoney (62 F.4th 108 (3d Cir. 2023)) and Stevens (70 F.4th 653 (3d Cir. 2023)): reaffirmed that completed Hobbs Act robbery—and Pinkerton conspiracy to commit it—satisfies § 924(c)’s elements clause.
Pinkerton v. United States (328 U.S. 640 (1946)): supports liability for reasonably foreseeable crimes committed in furtherance of a conspiracy.

2. Legal Reasoning

The Court’s reasoning grouped into several themes:

a. Administrative Warrant Use and Abel’s Bad-Faith Exception

The Fourth Amendment’s objective reasonableness standard generally tolerates administrative-warrant arrests when executed in good faith. Under Abel, only a showing that officers acted with an “entirely illegitimate purpose” defeats that good-faith presumption. Here, Maryland officers expressly sought to enforce a parole warrant; there was no evidence of clandestine criminal investigatory motive. Pennsylvania law enforcement’s sharing of location information did not transmogrify the administrative warrant into a pretext for homicide investigation.

b. Electronic Surveillance Orders and the Good-Faith Exception

Pennsylvania statutory defects alone do not trigger the federal exclusionary remedy; without a Fourth Amendment violation, suppression is unavailable. And because the cell-site location warrants pre-dated Carpenter, the good-faith exception (per Leon and Goldstein) applied.

c. Categorical Crime-of-Violence Analysis Under § 924(c)

The Court applied the “categorical approach” to statutory elements. Despite Taylor barring attempt convictions, completed Hobbs Act robbery remains a crime of violence under § 924(c)(3)(A). Stoney and Stevens confirm that all forms of Hobbs Act robbery categorically satisfy the physical-force requirement.

d. Evidentiary Rulings at Trial

– Rule 607 permits impeachment of any witness, including the prosecution’s own, so long as the primary purpose is assessing credibility—not evading hearsay rules. The Court found no abuse of discretion where lines of questioning fairly tested consistency with prior DEA statements.
– The residual hearsay exception (Rule 807) demands “exceptional guarantees of trustworthiness” and is to be invoked only sparingly. The district court reasonably concluded that statements by Chaney’s mother lacked the required reliability and necessity.

e. Sentencing and § 5K2.21 Upward Departure

Under § 5K2.21, sentencing courts may depart upward to reflect serious uncharged conduct. Here, the district judge relied on coconspirator testimony (observed firsthand at trial) and additional aggravating facts to impose statutory-maximum or life sentences. The Third Circuit held that:

Coconspirators’ corroborated trial testimony carried sufficient indicia of reliability;
The Confrontation Clause and the Federal Rules of Evidence do not bind the sentencing hearing;
The upward departure and consecutive life terms were procedurally and substantively reasonable.

3. Impact

This decision underscores and reinforces several legal principles:

Administrative warrants used in good faith remain a valid tool for parole enforcement, even when criminal investigators piggyback on location data.
State-law warrant defects will not yield federal suppression absent a Fourth Amendment breach.
Pre-Carpenter cell-site orders issued by a magistrate survive good-faith challenges.
Hobbs Act robbery’s classification as a crime of violence endures, guiding § 924(c) prosecutions in drug-and-violent-crime cases.
Sentencing courts may responsibly weigh reliable uncharged conduct via § 5K2.21, reinforcing robust departures for extreme aggravation.

Complex Concepts Simplified

Abel Bad-Faith Exception: Even administrative warrants must be used legitimately; if officers lie or secretly investigate criminal offenses, the warrant is invalid.
Good-Faith Exception (Leon): Evidence seized under a warrant later found invalid need not be suppressed if the executing officers reasonably relied on it.
Categorical Approach: To see if a prior conviction counts as a “crime of violence,” courts compare the statute’s elements, not the defendant’s actual conduct.
Residual Hearsay Exception: Allows rare admission of out-of-court statements when they carry high reliability and compelling necessity.
Upward Departure (§ 5K2.21): Judges can exceed the guidelines when a defendant’s real conduct—including dismissed or uncharged acts—is far worse than the charged offense suggests.

Conclusion

The Third Circuit’s affirmance in United States v. Coles, Preddy, and Jenkins-Armstrong reaffirms crucial limits on judicial intervention into administrative-warrant arrests, elaborates the contours of state versus federal suppression rights, cements Hobbs Act robbery’s status as a crime of violence for § 924(c), and validates the use of reliable co-conspirator testimony and sentencing-stage departures for exceptionally serious uncharged conduct. Collectively, these holdings bolster law enforcement cooperation, safeguard legitimate warrant practices, and provide clear guideposts for prosecutors and courts facing prosecutions that straddle drug trafficking, violent conspiracy, and witness–intimidation crimes.