United States v. Teslauch Gatkuoth

── United States v. Teslauch Gatkuoth ── Court: Court of Appeals for the Eighth Circuit Date: June 08, 2026 Category: General United States Court of Appeals For the Eighth Circuit ___________________________ No. 24-2536 ___________________________ United States of America Plaintiff - Appellee v. Teslauch K. Gatkuoth Defendant - Appellant ____________ Appeal from United States District Court for the District of Nebraska - Omaha ____________ Submitted: February 12, 2026 Filed: June 8, 2026 ____________ Before LOKEN, SMITH, and STRAS, Circuit Judges. ____________ STRAS, Circuit Judge. Sometimes truth really is stranger than fiction. Here, a routine traffic stop led to a foot chase that ended inside a stranger’s house, where officers arrested Teslauch Gatkuoth and discovered a pistol under some laundry in a child’s bedroom. Although he claims he was an overnight guest and that the gun did not belong to him, the evidence suggests otherwise.  I. A traffic stop turned into something more when officers tried to pull over a silver Lexus driven by Gatkuoth that had rolled through a stop sign. Rather than slowing down, he drove through a second one. Eventually, he stopped, jumped out, and made a run for it while clutching his waistband. When Gatkuoth reached a nearby home, he ran directly into a bedroom. After a brief standoff, he finally surrendered. As he did, an officer heard a child’s voice inside. Much to the officer’s surprise, the 8-year-old child said, “[h]e put some stuff in my room, bro, I don’t know what.” Turns out the “stuff” included a Taurus G3 9mm handgun found underneath some clothes in a laundry hamper. While the incident was unfolding, another resident, Riek Kuany, was calmly standing on the front porch. At first, he denied knowing Gatkuoth. The answer changed, however, during the suppression hearing on the gun. By then, Kuany was not only willing to swear he knew Gatkuoth, but that he had an open invitation to stay at the house. He was, in other words, a regular overnight guest. For a few reasons, the district court 1 found his testimony “less than convincing.” One was that no one else living at the house knew Gatkuoth despite his “purported multitude of stays at the residence.” Another was Kuany’s lack of information about him, even though they had allegedly known each other for years and were members of the same gang. And finally, some of his answers to basic questions seemed “rehearsed,” while he “struggled” with others. After the district court denied the motion to suppress, a jury found Gatkuoth guilty of illegally possessing the firearm. See 18 U.S.C. § 922(g)(1). 1 The Honorable Brian C. Buescher, United States District Judge for the District of Nebraska. -2-  II. In his view, the case should never have made it to a jury because the officers needed a warrant to search the child’s bedroom. “Standing” to object depended on whether Gatkuoth had “a legitimate expectation of privacy” in the place searched. United States v. Kuenstler, 325 F.3d 1015, 1020 (8th Cir. 2003); see United States v. Salvucci, 448 U.S. 83, 86 (1980) (explaining that the defendant has the burden to prove Fourth Amendment standing). The district court ruled that he had none because he was a stranger to the house, not even qualifying as an overnight guest. See Minnesota v. Olson, 495 U.S. 91, 98 (1990) (discussing overnight guests). Even if we assu