Case Explained: UNITED STATES OF AMERICA v. DANIEL SAMUEL ETA

Court: United States Court of Appeals for the Seventh Circuit

Filed: 2026-07-06

The Seventh Circuit affirmed the district court’s denial of Daniel Eta’s motion to suppress evidence obtained from a manual search of his cell phones at an international airport. The court held that brief, manual searches of electronic devices at the border are “routine” under the border search exception to the Fourth Amendment and therefore require neither a warrant nor individualized reasonable suspicion. Relying on its precedent in *United States v. Mendez*, the court rejected Eta’s argument that the search was non-routine due to its duration or scope, emphasizing that bright-line rules are necessary for administrative workability at the border. The court further ruled that the search did not require a “genuine border-related justification” on a case-by-case basis, as routine border searches are reasonable simply by virtue of occurring at the border. Additionally, the court stated that even if the search were deemed unconstitutional, the good-faith exception to the exclusionary rule would apply because law enforcement officers acted in objectively reasonable reliance on binding appellate precedent (*United States v. Wanjiku* and *United States v. Skaggs*) which did not require a warrant or probable cause for such searches at the time. The practical consequence is that the evidence remains admissible, Eta’s conviction stands, and his 109-month prison sentence is upheld.

Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.