United States v. Jason Procknow

TINDER, Circuit Judge.

DefendanWAppellant Jason Procknow pleaded guilty to one count of theft of government money, 18 U.S.C. § 641, and one count of aggravated identify theft, id. § 1028(a)(1), related to his filing of fraudulent tax returns claiming refunds. Procknow appeals the denial of his motion to suppress, having reserved the right to do so in his plea agreement. Procknow moved to suppress (1) evidence obtained after police officers’ warrantless entry into his hotel room following his arrest in the hotel lobby, and (2) evidence obtained by grand jury subpoena following the withdrawal of…