## Facts

- Christian Hartwell arrived at Philadelphia International Airport intending to board a flight to Phoenix.
- At the security checkpoint, Hartwell triggered the walk-through metal detector.
- Transportation Security Administration (TSA) screeners used a hand-held magnetometer (wand) to locate the source of the alarm.
- The wand indicated a solid object in Hartwell’s pocket, and the screener asked Hartwell to identify or display the object.
- The object was connected to crack cocaine discovered on Hartwell’s person.
- The parties disputed what happened during the secondary screening (including the sequence of requests, whether Hartwell cooperated, and whether screening moved to a private area).
- The district court credited the government’s version of the encounter and denied Hartwell’s motion to suppress the drugs under the Fourth Amendment.
- Hartwell entered a guilty plea that preserved his right to appeal the suppression ruling but included a waiver of appellate rights as to sentencing issues.
- At sentencing, Hartwell sought “safety valve” relief, which the district court denied.
- Hartwell appealed both the denial of suppression and the denial of safety-valve relief.

## Issues

1. Whether the TSA’s checkpoint screening of Hartwell—after he set off the metal detector and was subjected to wanding and follow-up inspection—violated the Fourth Amendment such that the crack cocaine should have been suppressed.
2. Whether Hartwell could appeal the denial of safety-valve sentencing relief despite an appellate-waiver provision in his plea agreement.

## Decision

- The Third Circuit held the search did not violate the Fourth Amendment and affirmed the denial of Hartwell’s motion to suppress.
- The court treated the magnetometer screening, wanding, and the attempt to resolve the unexplained object as part of a single airport checkpoint screening process directed at flight safety.
- Applying the administrative-search framework, the court held that individualized suspicion and a warrant were not required for routine airport screening conducted under a neutral security program.
- The court concluded the additional screening steps were reasonable in scope given the metal-detector alarm and the unresolved object indicated by the wand.
- The court enforced Hartwell’s plea-based appellate waiver and declined to reach the merits of his safety-valve challenge.
- The judgment of conviction and sentence was affirmed.

## Legal Principles

- Airport checkpoint screening is an administrative search subject to the Fourth Amendment’s reasonableness requirement, justified by a regulatory public-safety purpose rather than ordinary criminal investigation.
- A checkpoint search may be reasonable without a warrant or individualized suspicion when conducted under a neutral program aimed at detecting weapons or explosives and limited to what is needed to address security concerns revealed during screening.
- Follow-up measures after a magnetometer alarm (including wanding and inspection of an unresolved object) can fall within the permissible scope of an airport administrative search.
- Contraband discovered during a lawful administrative screening is not excluded merely because it is not itself a weapon or explosive.
- A plea agreement may validly waive appellate review of sentencing issues when the waiver is knowing and voluntary, and the waiver will generally be enforced absent a miscarriage of justice.

## Conclusion

The Third Circuit held that TSA screeners acted within the Fourth Amendment by conducting routine checkpoint screening and reasonable follow-up measures after Hartwell triggered the metal detector, and it enforced Hartwell’s plea-agreement waiver to bar appellate review of the district court’s denial of safety-valve sentencing relief.


United States v. Hartwell, 436 F.3d 174 (2006)