Full opinion text
THOMPSON, Circuit Judge. After a jury convicted Defendants-Appellants José Laureano-Salgado, Pedro Ramirez-Rivera, and Ismael Cruz-Ramos (collectively, “the Defendants”) of numerous drug and gun crimes, a district court judge sentenced them all to life in prison. The Defendants now ask us to overturn their convictions and sentences, or, at the least, send their case back for a new trial. For the reasons discussed below, we reverse Cruz-Ramos’s conviction and sentence and remand jhis case for a new trial. We affirm Laureano-Salgado’s and Ramirez-Rivera’s convictions and sentences. BACKGROUND To give a lay of the land, we start with only a brief overview of this case. We fill out relevant portions of the story — in, as we invariably explain, whatever light our law demands, and relying on whatever record support is appropriate — as they are needed throughout our analysis of the various issues the Defendants have raised. How It Began Until 2004, the majority of street-level drug sales in the San Juan-metropolitan area of Puerto Rico were controlled by gangs operating out of public housing projects. Sales in each housing project were generally controlled by each project’s own drug gang. The name of the game back then was control of the drug points, and the gangs fought for decades to maintain and grow their territories. The violence that accompanied their disputes naturally drew the attention of both local and federal authorities. As a result, drug sales took a hit, and large conspiracy indictments were handed down. Around 2004, nearly all the drug gang leaders from the area reached an agreement that to reduce the inter-project conflicts and keep the cops away, they would form an alliance. They named it “La Organización de Narcotraficantes Unidos” (Spanish for “The Organization of United Drug Traffickers”), or “La ONU” for short. The leaders agreed that if a conflict arose among La ONU members, they would meet to discuss it (as opposed to immediately resorting to shootouts). Under the new regime, La ONU members would be permitted to visit other La ONU-affiliated housing projects (and to also sell drugs there), so long as they got permission from that project’s leader. The La ONU leaders also met regularly to discuss drug-related issues and to resolve conflicts, While the alliance operated “for a time,” for reasons unknown it “weakened” as eertain gangs grew “disgruntled” with La ONU and “sought to break off.” Sometime around 2008, La ONU ended up breaking into two groups — La ONU and “La Rompe ONU” (known as “La Rompe” for short, which translates to “the break”). Each project-gang went all-in with either La ONU or La Rompe. La ONU-controlled projects included Las Dalias, Las Gladiolas, El Prado, and Los Jardines de Selles, while La Rompe-eontrolled projects included Trujillo, Cupey, and Alturas de Cupey. The two factions soon became equally sized and eventually, they became bitter rivals. With the rising of La Rompe, La ONU’s direction changed. Its mission became to “maintain control over the drug points in their housing projects by force and to kill La Rompe members and leaders in order to expand.” The organization’s “unwritten” rules required that La ONU members remain loyal to each other, while relentless to the enemy. La ONU members could not kill other La ONU members without go-ahead from the leadership; nor could they overtake La ONU-owned drug points. Not only were La ONU members forbidden from associating with La Rompe members, they were also required to kill them on-sight. La ONU members were not permitted to cooperate with law enforcement. And breaking any of these rules meant death to the traitor (and/or his family members). La ONU leaders continued to meet with each other to resolve internal conflicts and discuss strategy for overtaking drug points at other (La Rompe-eontrolled) housing projects. They regularly pooled resources to buy weapons and cars. When attacks on La Rompe members would go down, each La ONU project contributed an enforcer (i.e., hit man). La ONU also continued to traffic drugs (crack, cocaine, heroin, and marijuana) and committed various violent acts (including murders) to enforce its rules and grow its territory. For instance, La ONU put hits out on La Rompe leaders. La ONU launched machine-gun shootouts in La Rompe projects. During one such shootout near Trujillo Alto Bridge, two women — a police officer and librarian — were killed. La ONU was also connected to the May 2010 shooting take-down of a police helicopter, allegedly committed by Edwin Bernard Astacio Espino (“Bernard”), a La ONU member. Betraying La ONU called for an equally devastating fate. For instance, when a La ONU member stole a gun and gave it to a La Rompe member, he too, was killed. So was a La ONU leader who got caught stealing drugs from the organization, and a member who cooperated with police. After the helicopter shooting, an arrest warrant was issued for Bernard (whom the police apparently could not find). The police caught a lucky break in August 2010, when an informant tipped them off that Bernard was hiding out at Cruz-Ramos’s house, stashing weapons and drugs. Afraid they would miss the chance to arrest Bernard if they waited any longer, the police searched Cruz-Ramos’s house (without a warrant), found Bernard, arrested him (and the several other people in the house, including Cruz-Ramos), and seized the drugs and guns they found at the home. Police also arrested other La ONU members for various crimes around 2010 to 2011. The Crackdown With that, in March 2012, a grand jury indicted 33 people for their alleged involvement in La ONU from 2004 through March 2012. The charges included drug trafficking, firearms crimes, murder, and attempted murder. The indictment accused all the Defendants of being members of La ONU. Amongst the indictment’s 33 counts, the Defendants here were charged with five: • Count 1: racketeering conspiracy from 2004 through March 2012, in violation of the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1962(d); • Count 2: conspiracy to possess with intent to distribute a controlled substance, in violation of 21 U.S.C. §§ 846 and 860; • Count 3: conspiracy to possess firearms during and in relation to narcotics trafficking offenses, in violation of 18 U.S.C. § 924(o); • Count 29: violent crime in aid of racketeering activity, in violation of 18 U.S.C. § 1959(a)(1) (specifically, for the August 2010 murder of Christian Toledo-Sánchez, known as “Pequeque”); and • Count 30: use and carry of a firearm in relation to a crime of violence (i.e., Pequeque’s murder), in violation of 18 U.S.C. §§ 924(c)(1)(A) and 924(j)(l). Pre-Trial Motions Puerto Rico District Court Judge José A. Fusté was assigned to preside over the 33-person case, but at some point the in-dieted defendants were split up into two groups for purposes of trial (one group being the defendants who were facing the death penalty, and the other group being the defendants who were not). Judge Fusté presided over the trial of the death-eligible defendants, and Judge William E. Smith, a Rhode Island district judge, sat in designation to preside over the trial of the non-capital defendants (including Cruz-Ramos, Laureano-Salgado, and Ramirez-Rivera). Judge Smith also addressed many of the numerous pre- and post-trial issues that arose for the non-capital group. As motion practice took way, and as jury selection in the Defendants’ case lingered imminent, the government asked the district court to empanel an anonymous jury because the Defendants were “part of an organized crime ring that is both willing and able to intimidate and harm jurors.” Over the Defendants’ constitutional objections, Judge Fusté (who was in charge of jury selection, even though he did not preside over the non-capital Defendants’ trial) allowed the motion in-part, and resolved to place the seated jurors’ names, addresses, and places of employment under seal because the Defendants hi fact had “shown that they are part of an organized crime ring that is both willing and able to intimidate and harm jurors.” The judge also ordered the jurors not to divulge information during voir dire that would disclose their identities. Shortly after that motion was resolved, the government notified the Defendants and the court that it intended to offer as evidence at trial the firearms and drugs that police seized from Cruz-Ramos’s home in August 2010. Cruz-Ramos moved to suppress all that evidence, arguing that the warrantless search of his home was illegal. After a two-day evidentiary hearing, Judge Smith denied in-part the motion to suppress. Jury Empanelment Judge Fusté empaneled the jury for the non-capital trial on January 23, 2013, several days before the trial was scheduled to start. The instant Defendants and their attorneys were present for jury selection. During voir dire (i.e., the process during which the court questions the potential jurors to determine whether they are fit to sit on the jury), Judge Fusté informed the potential jurors that their names, addresses, and places of employment would be kept anonymous, and that they would each be assigned an identifying number to “ward off curiosity and seekers of information that might otherwise infringe on [their] privacy.” The judge asked the jurors numerous questions during voir dire, and instructed them to raise their hands if the answer was “yes” to any of the questions, after which point the court would individually address their concerns. Among numerous other topics, the judge asked a question about the jurors’ familiarity with the 2010 police helicopter shooting. He informed the jurors that while La ONU was “associated” with the incident, the shooting would not come up during the trial because the Defendants were not charged with that shooting. Some of the jurors raised their hands in response to the question, and the judge followed up with them individually. After voir dire concluded, the jury (including alternates) was selected. But a few days before the start of trial, Juror No. 30 wrote a letter to the court asking to be excused because she was experiencing anxiety from having to sit on the jury. In response, the Defendants asked the court to conduct further voir dire of all the empaneled jurors, contending that Juror 30 could have “infected” the other jurors “by creating bias against” them. Judge Fusté decided to interview Juror 30 (outside of the Defendants’ presence, though their lawyers were allowed to be there) and concluded that she was unfit to serve on the jury for mental health reasons (essentially, she was intimidated by the Defendants). After the interview, Judge Fusté dismissed the juror and replaced her with an alternate. He also denied the Defendants’ request to individually poll the other empaneled jurors. The Trial and Sentencing Judge Smith got started with the Defendants’ trial on February 7, 2013. Among the evidence the government presented was testimony from law enforcement and cooperating La ONU members, as well as physical evidence police seized, like guns and drugs. After seven days, the jury convicted the Defendants on all counts. The Defendants then moved for either an acquittal or a new trial based on lack of sufficient evidence, pursuant to Federal Rules of Criminal Procedure 29(a) and 33. Judge Smith denied the motions, finding that the government’s presentation of witness testimony and physical evidence “strongly supported” the convictions. In October 2013, Judge Smith sentenced all the Defendants to life in prison. Now on appeal the Defendants argue that numerous errors occurred prior to and during the trial, such that their convictions should be vacated — nr at the least that they should get a new trial. Assuming those arguments do not convince us, the Defendants further argue that their sentences were improper for various reasons. We address each of the Defendants’ many arguments in turn. DISCUSSION I. Sufficiency of the Evidence We begin our task by addressing whether the evidence put before the jury was sufficient to convict the Defendants. We tackle this issue first because if the Defendants are right, the remedy is about as drastic as they come — we would have to throw out their convictions, and because of the Double Jeopardy Clause of the Fifth Amendment, the government would not get another shot at re-trying them on these charges. See United States v. Negrón-Sostre, 790 F.3d 295, 306-07 (1st Cir. 2015). Of course, a successful sufficiency challenge would then render all the Defendants’ other claims (of reversible trial and sentencing error) moot. We review sufficiency challenges de novo. Id. at 307. We consider all the direct and circumstantial evidence in the light most flattering to the government, “drawing all reasonable inferences consistent with the verdict, and avoiding credibility judgments, to determine whether a rational jury could have found the defendants guilty beyond a reasonable. doubt.” Id. (internal quotation marks and alteration omitted). Essentially, “we will reverse only if the verdict is irrational.” United States v. Brandao, 539 F.3d 44, 50 (1st Cir.2008) (internal quotation marks omitted). In reviewing sufficiency challenges, we consider whether all the evidence offered by the government and admitted by the court was sufficient for a guilty verdict, even if the court erroneously admitted some of that evidence. Lockhart v. Nelson, 488 U.S. 33, 34, 40-41, 109 S.Ct. 285, 102 L.Ed.2d 265 (1988). Turning now to the evidence, there’s no question that the government’s case against the Defendants (particularly when it came to Laureano-Salgado and Ramirez-Rivera) heavily relied on testimonial evidence from three cooperating witnesses who were arrested around 2011 for their involvement with La ONU — Christian Figueroa-Viera, a hit man and “leader” for La ONU; José Gutierrez-Santana, known as “El Domi,” who sold drugs for the organization; and Wesley Figueroa-Cancel, also known as “Hueso,” who was also a La ONU leader. The allegations in the indictment largely ended up panning out at trial. According to the witnesses’ testimony, from around 2007 to 2011, La ONU operated as a “union” or “gang” of drug dealers from several housing projects (including Las Dalias, Las Gladiolas, El Prado, and Los Jardines de Selles), which had the goal of “controlling] the other housing projects and thus have more power.” La ONU’s main rival was La Rompe, which controlled projects like Trujillo, Cupey, and Alturas de Cupey. The two gangs were at “war” over the “control of the drug points.” Dominating the drug points was important to La ONU for a simple reason: by eliminating the competition in the La Rompe-controlled projects, La ONU could earn more drug money. To effectuate its goals, La ONU had rules. If you see an enemy, kill him. Don’t cooperate with police. And don’t associate with the enemy. The punishment for breaking a rule was death. The evidence showed that La ONU walked the walk, and not only were La Rompe members attacked and killed, disloyal La ONU were in fact punished by death. For instance, around 2008 or 2009, a La ONU member stole a rifle and gave it to a La Rompe member. After he confessed to giving the rifle to the enemy, La ONU members killed him. In 2009, a La ONU leader was killed for stealing drugs from the organization. And yet another La ONU member was killed for cooperating with police. The witnesses testified that it was important to participate in these types of violent acts to maintain their status with La ONU, even though that might mean killing police officers. It was necessary for members to maintain their positions in La ONU because “once you join the organization, you can’t get out.” The testimony also demonstrated that Defendant Ramirez-Rivera was the heroin point owner in both Las Gladiolas and Las Dalias, as well as a La ONU leader. Ramirez-Rivera was so high up in the organization that without his permission, “nothing could be done,” according to Gutierrez-Santana. And Ramirez-Rivera ordered other La ONU members to kill La Rompe associates. In addition to supplying heroin, weapons, and ammunition to the organization, Ramirez-Rivera also provided the cash to buy weapons and cars. And he sometimes lent his own gun to La ONU members when they went to other projects for a shooting. From around 2008 to 2011, Defendant Laureano-Salgado served as Ramirez-Rivera’s drug runner (meaning he brought product to drug points and picked up the money the drug points earned), and was a cocaine point owner at Las Gladiolas. Defendant Cruz-Ramos was a heroin point owner at Las Gladiolas and provided firearms to the La ONU members who were from Las Gladiolas. He also lent weapons, including an AK-47, to other La ONU members. To prepare for shootouts, La ONU generally held meetings, which were always conducted by the same people (including Cruz-Ramos, Ramirez-Rivera, and Laureano-Salgado). The government also elicited testimony about several La ONU-sanctioned murders, but at trial the Defendants were only directly implicated in one — the murder of La Rompe boss Christian Toledo-Sánehez, a.k.a. Pequeque. The testimony reflected that in August 2010, La ONU put a hit out on Pequeque. A meeting (which the Defendants participated in) was held to hash out the details of the murder with the for-hire hitman, whose grandmother was Pequeque’s neighbor. During the attack on Pequeque (who was, in fact, killed), the hitman was injured, and the Defendants were part of the extraction team that went in to rescue him. A. RICO Conspiracy (Count One) Given that evidentiary backdrop, we first address the sufficiency of the evidence as to the Defendants’ RICO conspiracy conviction under 18 U.S.C. § 1962(d). The Racketeer Influenced and Corrupt Organizations Act, or “RICO,” makes it “unlawful for any person employed by or associated with any enterprise engaged in, or the activities of which affect, interstate or foreign commerce, to conduct or participate, directly or indirectly, in the conduct of such enterprise’s affairs through a pattern of racketeering activity or collection of unlawful debt.” 18 U.S.C. § 1962(c). Section 1962(d) also prohibits any person from conspiring to violate § 1962(c). “The major difference between a violation of § 1962(c) itself and a violation of § 1962(d) based on § 1962(c) is the additional required element that the defendant knowingly joined a conspiracy to violate § 1962(c).” United States v. Shiftman, 124 F.3d 31, 35 (1st Cir.1997) (citation and alterations omitted). Thus, “[f]or a defendant to be found guilty of conspiring to violate RICO, the government must prove (1) the existence of an enterprise affecting interstate [or foreign] commerce, (2) that the defendant knowingly joined the conspiracy to participate in the conduct of the affairs of the enterprise, (3) that the defendant participated in the conduct of the affairs of the enterprise, and (4) that the defendant' did so through a pattern of racketeering activity by agreeing to commit, or in fact committing, two or more predicate offenses.” Id. (internal quotation marks and alteration omitted). Here, the Defendants argue that the evidence was not sufficient for elements one, three, and four. For the reasons discussed below, we find no merit to this claim. Enterprise Affecting Foreign Commerce To start off, the Defendants’ argument that the government presented insufficient evidence that La ONU was a RICO enterprise affecting interstate or foreign commerce carries no water. RICO defines an enterprise as “any individual, partnership, corporation, association, or other legal entity, and any union or group of individuals associated in fact although not a legal entity.” 18 U.S.C. § 1961(4). Thus, an enterprise “need only be a group of persons associated together for a common purpose of engaging in a criminal course of conduct,” and “need not be a legitimate business or a form of organization sanctioned by state law.” United States v. Nascimento, 491 F.3d 25, 32 (1st Cir.2007) (internal quotation marks omitted). Still, even though such an “association in fact” suffices to satisfy the “enterprise” requirement, see 18 U.S.C. § 1961(4), the law is clear that “the government nonetheless must prove that the enterprise existed in some coherent and cohesive form.” Nascimento, 491 F.3d at 32. “It follows that the enterprise must have been an ‘ongoing organization’ operating as a ‘continuous unit.’ ” Id. (citation omitted). Put simply, a RICO enterprise “possesses some goal or purpose more pervasive and more enduring than the instant gratification that can accrue from the successful completion of each particular criminal act.” Id. Here, the government presented more than sufficient evidence that La ONU operated as an enterprise. Even if the Defendants are correct that La ONU started off as a truce between the different housing-project gangs, those groups concertedly combined their efforts for a specific, ongoing purpose — in the beginning, to sell drugs, and later, to also stomp out the competition (specifically, La Rompe). This super-gang, if you will, although a merging of smaller gangs that still operated their existing drug points, became “ongoing and identifiable” by its name; the organization even had a special hand gesture (i.e., gang sign). See United States v. Patrick, 248 F.3d 11, 19 (1st Cir.2001) (finding that an enterprise existed where the “gang was ongoing and identifiable” by name and gang sign). La ONU also had rules and structure. Truant members and enemies were killed, but not before leaders first signed off on the killings. Before committing acts of violence on behalf of the organization, members had to get permission from La ONU leaders, who hosted meetings to discuss shootouts before they were carried out. See id. (taking into account that the enterprise “had ‘sessions’ where important decisions were made, including decisions about taking action against rival drug dealers”). Therefore, while the Defendants urge that the La ONU organization did not have all the traditional indicia of a typical street gang (e.g., use of colors, initiation rites, and a formal hierarchy), as the Supreme Court has pointed out, RICO’s “enumeration of included enterprises is obviously broad,- encompassing ‘any ... group of individuals associated in fact.’ ” Boyle v. United States, 556 U.S. 938, 944, 129 S.Ct. 2237, 173 L.Ed.2d 1265 (2009) (quoting 18 U.S.C. § 1961(4)). “The term ‘any' ensures that the definition has a wide reach, and the very concept of an association in fact is expansive.” Id. (citation omitted). As we fleshed out above, La ONU “exhibited group cohesion over time; its membership pooled and shared resources; the individuals involved had a sense of belonging and self-identified as [La ONU] members; and the group had a well-honed set of goals.” Nascimento, 491 F.3d at 33. We deem that more than enough for a RICO enterprise. See id. Further, we also easily find that La ONU engaged in or conducted activities that affected foreign commerce. See 18 U.S.C. § 1962(c). We have said before that an enterprise’s effect on commerce need only be de minimis, given that the commerce requirement is only jurisdictional. United States v. Marino, 277 F.3d 11, 35 (1st Cir.2002). Gutierrez-Santana testified that during his time as a La ONU member from about 2009 until his arrest in 2011, he imported kilos of heroin from the Dominican Republic to provide to La ONU drug points (and in particular to Ramirez-Rivera). This activity is sufficient to satisfy RICO’s foreign commerce requirement. Participation RICO also requires the government to prove that the Defendants participated in the conduct of the enterprise’s affairs. According to the Supreme Court, that means “participation in the operation or management of the criminal enterprise.” Shifman, 124 F.3d at 35-36 (quoting Reves v. Ernst & Young, 507 U.S. 170, 184-85, 113 S.Ct. 1163, 122 L.Ed.2d 525 (1993)). It suffices for this element that a defendant be “plainly integral to carrying out the enterprise’s activities.” Id. at 36 (internal quotation marks omitted). Despite the Defendants’ attempts to dilute the rather damning evidence of their active leadership roles in La ONU, we find that this element was also clearly satisfied. As we discussed above, the testimony reflected that all three Defendants owned drug points in La ONU-controlled projects. Of course, drug-point ownership was a vital component to the La ONU conspiracy, given that the whole point of the enterprise was to maintain control of as many drug points as possible to earn more money. On these facts alone, we conclude the jury had abundant reason to find that the Defendants were integral parts of the enterprise’s activities. Pattern of Racketeering Finally, the Defendants contend that there was insufficient evidence that they participated in the conspiracy by agreeing to commit (or actually committing) a pattern of racketeering activity. Not so. To satisfy the “pattern” element for a RICO conspiracy, the statute requires that “a defendant agreed with one or more others that two predicate offenses be committed.” Shifman, 124 F.3d at 35 (internal citation and alteration omitted). RICO specifically enumerates what counts as a “predicate offense,” and includes (among many other crimes) murder and drug dealing. See 18 U.S.C. § 1961(1). “Aiding and abetting one of the activities listed in § 1961(1) as racketeering activities makes one punishable as a principal and amounts to engaging in that racketeering activity.” Shifman, 124 F.3d at 36 (citing 18 U.S.C. § 2). RICO also requires that the defendant commit the two racketeering acts within 10 years of one another. 18 U.S.C. § 1961(5). Additionally, the Supreme Court has said that the “acts must be related and ‘amount to or pose a threat of continued criminal activity.’ ” Shifman, 124 F.3d at 36 (quoting H.J. Inc. v. Nw. Bell Tel. Co., 492 U.S. 229, 239, 109 S.Ct. 2893, 106 L.Ed.2d 195 (1989)). We conclude that the evidence was sufficient for the jury to find that each of the Defendants participated in La ÓNU by agreeing to engage in a pattern of racketeering. First, despite the Defendants’ representation to the contrary, there was witness testimony that all the Defendants were part of the 2010 planning meeting for Pequeque’s murder. The jury heard testimony that during the planning meeting, which Cruz-Ramos and Laureano-Salgado attended and Ramirez-Rivera participated by speakerphone, the leaders decided that Pequeque would be killed by a particular hitman with $10,000 of La ONU funds, as well as a La ONU-provided pistol and car. The jury could easily infer, given the body of testimony they heard, that the reason for Pequeque’s murder was to enforce La ONU’s ongoing mandate that La Rompe members be executed, so that La ONU could expand its territory. Second, as we noted above, the record reflected evidence that each Defendant, as drug point owners, engaged in drug trafficking for La ONU-controlled drug points between 2007 and 2011. See 18 U.S.C. § 1961(1) (listing “dealing in a controlled substance” as a RICO predicate). The Defendants do not seriously dispute this point either, arguing only that their drug-selling at the individual drug points “did not contribute to La ONU’s objectives” because the drugs were sold only for the benefit of the individual gangs at each housing project. We have already rejected the Defendants’ notion that selling at the individual housing projects did not contribute to La ONU’s mission to take over the drug market, but even if the Defendants’ sales did not directly financially benefit La ONU, their claim would still fail. It suffices that “the defendant was able to commit the predicate acts by means of, by consequence of, by reason of, by the agency of, or by the instrumentality of his association with the enterprise.” Marino, 277 F.3d at 27. “[T]he defendant need not have channeled the proceeds of the racketeering activity into the enterprise,” and “[i]t is unnecessary for the pattern of racketeering to have benefitted the enterprise in any way.” Id. at 28. Particularly given the ensuing “war” with La Rompe over the drug points, the jury could have reasonably inferred that the Defendants’ drug-trafficking success (i.e., their ability to survive) was attributable to their alliance with, allegiance to, and high-ranking status in La ONU. All in all, the RICO conviction stands. B. VICAR (Count 29) In a similar vein, the Defendants unconvincingly argue that the jury heard insufficient evidence to sustain their conviction for Violent Crime in Aid of Racketeering Activity (“VICAR”) under 18 U.S.C. § 1959(a). VICAR prohibits murder (or conspiracy to commit murder) “for the purpose of gaining entrance to or maintaining or increasing position in an enterprise engaged in racketeering activity. 18 U.S.C. § 1959(a). The predicate offense for the Defendants’ VICAR conviction was Pequeque’s murder (which the indictment charged as a violation of Puerto Rico law), and the Defendants once again argue that there was insufficient evidence that any of them were involved in that murder. But for the reasons discussed earlier we reject that argument, as the jury could have reasonably inferred that the Defendants themselves planned Pequeque’s murder. And that is sufficient for a murder conviction under Puerto Rico law. See Puerto Rico Penal Code Articles 105 and 106 (respectively, P.R. Laws Ann. tit. 33, §§ 4733, 4734 (2004). As to the second VICAR element, the Defendants have provided no developed reasoning as to why the trial evidence would not suffice to show at least part of their motive for the murder was to “advance or maintain their position within” La ONU. See United States v. Zannino, 895 F.2d 1, 17 (1st Cir.1990) (noting that undeveloped arguments are waived). We need not tarry on this point. The VICAR conviction stands. C. Conspiracy to Possess Firearms (Count 30) For the Defendants’ last sufficiency challenge, they urge that they were improperly convicted of conspiring to possess firearms because none of the guns that were introduced or mentioned at trial actually belonged to La ONU. 18 U.S.C. § 924(o) provides that “[a] person who conspires to commit an offense under [18 U.S.C. § 924(c) ] shall be imprisoned for not more than 20 years, fined under this title, or both; and if the firearm is a machinegun or destructive device, or is equipped with a firearm silencer or muffler, shall be imprisoned for any term of years or life.” And 18 U.S.C. § 924(c)(1)(A) provides a minimum imprisonment term for any person who, during and in relation to any crime of violence or drug trafficking crime (including a crime of violence or drug trafficking crime that provides for an enhanced punishment if committed by the use of a deadly or dangerous weapon or device) for which the person may be prosecuted in a court of the United States, uses or carries a firearm, or ... in furtherance of any such crime, possesses a firearm. The Defendants argue that there was no evidence presented that they used or carried firearms “in furtherance” of a crime of violence or drug-trafficking crime, and that “mere presence of a firearm in an area where a criminal act occurs” does not suffice. See United States v. Bobadilla-Pagán, 747 F.3d 26, 35 (1st Cir.2014). Again, the Defendants miss the mark. “For purposes of 18 U.S.C. § 924(c)(1)(A), we have understood ‘in furtherance of to demand [a] showing [of] a sufficient nexus between the firearm and the drug crime [or crime of violence] such that the firearm advances or promotes the drug crime [or crime of violence].” United States v. Gurka, 605 F.3d 40, 44 (1st Cir.2010) (internal quotation marks omitted). Here, even if the guns put into evidence during the trial did not belong to the Defendants, the jury heard evidence that all the Defendants carried firearms and/or supplied them to the organization from 2008 to 2011. And the jury could easily conclude that given La ONU’s mission to protect its drug territory, and its tendency to do so through gun violence, the firearms that drug point owners carried or provided to other members either advanced or promoted their drug-trafficking businesses. Thus, that no weapons were ever seized directly from Laureano-Salgado or Ramirez-Rivera is of no consequence when it comes to\iur sufficiency analysis — “[testimony from even just one witness can support a conviction.” Negrór-Sostre, 790 F.3d at 307 (internal quotation marks omitted). In sum, we find that the evidence was abundantly sufficient to convict the Defendants of the contested crimes.. II. Reversible Trial Errors Because we find that the evidence presented to the jury was sufficient to support the Defendants’ convictions, we now turn to the Defendants’ allegations regarding supposed errors that might warrant a new trial. Specifically, Cruz-Ramos argues that the district court erred in denying the motion to suppress the August 2010 search of his home that led to his arrest, the seizure of numerous guns and large amounts of drugs, and the arrest of Bernard and several other people in the house. The Defendants, also collectively argue that the district court erred during jury selection and in making certain evidentiary rulings at trial. A. Cruz-Ramos’s Motion to Suppress To start us off, Cruz-Ramos claims that the district court erroneously denied his motion to suppress the fruits of the 2010 police search of his home (and the car garaged there), as the police had no probable cause to enter his home without a warrant, let alone to search. He also argues that the statements he made to police after the search (and his subsequent arrest) should also be suppressed as fruits of the poisonous search. Because we agree with Cruz-Ramos that probable cause was lacking and therefore the search of the home and car violated the Fourth Amendment, we find that the evidence seized during the search should have been suppressed. We also conclude that including the erroneously admitted evidence at trial was not harmless, given the lack of other compelling evidence linking Cruz-Ramos to drug crimes, and thus, a new trial for Cruz-Ramos is warranted. . District Court Decision Based on the testimony from three law enforcement agents (the only witnesses to testify at the suppression hearing), the district court made the following factual findings. See United States v. Beras, 183 F.3d 22, 24 (1st Cir.1999) (“In reviewing the court’s denial of defendant’s motion to suppress, we recite the facts as found by the district court to the extent they are not clearly erroneous.”). On August 28, 2010, Puerto Rico Police Department Officer Carlos A. Jimenezs Rolon showed up at Las Dalias housing project around 2:30 a.m. to conduct a “preventative round” (Las Dalias had one of the highest crime rates of the island’s housing projects). During the round, Officer Jimenez-Rolon saw a man walking. The Officer got out of his (marked) car and told the man to stop. Instead of complying, the man took off running. Officer Jimenez-Rolon gave chase. The man reached into his pocket and threw an unidentified object toward the second story of the nearby building. Office Jimenez-Rolon realized he wouldn’t be able to catch the fleer, so instead went to investigate what the man had purged from his pocket. Officer Jimenez-Rolon went up to the second floor of the nearby building and discovered a different man lying down (presumably in the hallway), with a firearm at his side. Officer Jimenez-Rolon arrested this man and took him to the police station. At the police station, Officer JimenezRolon began to interview the arrested man. The arrestee told Officer JimenezRolon that if the police could provide security to his family, he would tell them where to find Bernard, one of Puerto Rico’s most-wanted fugitives for allegedly shooting down the municipal helicopter. Officer Jimenez-Rolon brought his supervisor, Lieutenant Luis David Flores-Ortiz, into the loop, and Lieutenant Flores-Ortiz agreed to the deal and continued with the interview. Lieutenant Flores-Ortiz had not met or spoken to the man prior to this encounter, and as far as the Lieutenant knew, the man had never previously served as an informant to the Puerto Rico police. The arrestee (who we’ll call from now on “the Informant”) told Lieutenant Flores-Ortiz that Bernard was hiding at a house in the Berwind Estates housing subdivision in Rio Piedras with at least four other people — Cruz-Ramos, two females, and perhaps other unidentified males. Bernard would have on him “many weapons, firearms, and controlled substances,” the Informant warned. Four rifles would also be hidden in a flower box on the terrace, and sidearms (like Berettas and Glocks) and drugs would be in a hidden compartment in a red Ford Expedition. The Informant did not provide any further details concerning what police would find at the home, nor a description of the house. The Informant said Bernard wouldn’t stick around for long and would depart at sun-up through the back of the house. The Informant further warned that Bernard would open fire at the police as soon as he saw them. Upon leaving the Berwind Estates home, Bernard would head for the Las Dalias housing project, the Informant claimed, “at which point the PRPD would lose their opportunity to arrest him” that night. The brief interview ended sometime between 3:30 and 4:00 a.m. Despite the fact that neither the Puerto Rico police nor Lieutenant Flores-Ortiz had any prior relationship with the Informant, the Lieutenant deemed him reliable based on the fact that both the Informant and Bernard “came from the Las Dalias housing project, and thus the Informant could likely be part of Bernard’s ‘close-knit’ group and know Bernard’s whereabouts.” With that, shortly after the interview ended, Officer Jimenez-Rolon drove the Informant to the house where Bernard was supposedly located. After they reached Berwind Estates and passed a manned security hut, the Informant pointed out a “good-sized residence” with “lots of vegetation” behind and to the side of it. The vegetation was relatively thick, but someone hiding in the bushes could still be seen from certain angles. A terrace with a flower box was also visible. Apparently satisfied with what he had observed, Officer Jimenez-Rolon took the Informant back to the police station, and around 5:00 a.m., the police returned to the house to arrest Bernard. They did not attempt to obtain either a federal or local search warrant to enter or search the home. After the police secured the home’s perimeter (and extended the perimeter out to the guardhouse), an “entry team” comprising six officers “entered through the property through the vegetation on the side of the house, crossed over the terra-cotta floored portion of the carport driveway, and proceeded to the door located on the side terrace.” To enter the carport, the officers “had to jump a cement wall,” and to enter the terrace, they opened a closed gate. From the terrace, the officers saw through a window an unidentified female sitting in the kitchen. They told her they were police, instructed her to stay silent, and asked her to open the door. She complied. They asked the woman where Bernard was, and she said he was in the bedroom. While the police made their way to the bedroom, other men (including Cruz-Ramos) appeared out of adjacent rooms. The officers detained them. The police continued into the bedroom, where they found Bernard in a bed “either asleep or just half-awake.” Close by Bernard was a pistol. They arrested him. All of the detained people were also arrested for harboring a fugitive. With everyone under arrest and the house secure, Officer Jimenez-Rolon searched the flower box on the terrace, where he found hidden under the dirt four rifles. Then he went in the house, walked through the foyer and through a glass door that opened into the carport, where a red Ford Expedition was parked. In the car, Officer Jimenez-Rolon found a hidden compartment with weapons, ammo, and drugs. Officer Jimenez-Rolon seized all of the drugs and guns he found. Cruz-Ramos, along with the other arrestees, was taken to the police department following his arrest. Sometime between 10:30 a.m. and noon, Cruz-Ramos was placed in a “small room” with three federal agents for an interview, which was not recorded. Cruz-Ramos was verbally apprised of his constitutional rights (particularly, his right to remain silent and his right to an attorney), and while he acknowledged that he understood them, he refused to sign any paperwork waiving his rights. The police proceeded to interview Cruz-Ramos anyway, and he told the agents that he lived in the house where he and Bernard were arrested, but that he was originally from the Las Gladiolas housing project. He admitted to being “affiliated with a group of housing projects that were partners and supported each other.” Cruz-Ramos also admitted to carrying a gun for personal defense and to having numerous rifles “hidden or buried somewhere.” He told the agents that he knew Bernard because they hung out together in different bars, and Bernard was acquainted with his stepdaughter. Cruz-Ramos said he knew Bernard was wanted by the police and had tried to arrange for Bernard to find a lawyer and surrender himself. Based on all these facts, the district court concluded that the police had probable cause to search Cruz-Ramos’s home without a warrant. Specifically, the court found that “[although the Informant had never provided information before, and only offered the information upon his arrest and interrogation, all of the other facts and circumstances support the [police’s] conclusion that the Informant was indeed truthful and reliable.” Those facts were: the Informant was arrested in Las Dalias, “a housing project that Bernard was associated with”; the Informant provided very detailed information; the Informant agreed to travel with Officer Jimenez-Rolon to “point[] out the precise residence, which matched the description he had already provided”; and the Informant put himself in danger by providing the tip. The court also found that exigent circumstances were present, namely, Bernard’s risk of escape and the threat he posed to public safety. Additionally, the court concluded that the warrantless search of the Ford Expedition was legal, as the Informant had provided a basis for probable cause that guns and drugs were hidden in it. While the court found no exigency, it nonetheless denied suppression of the car-search based on the “auto exception” to the warrant requirement. See United States v. Polanco, 634 F.3d 39, 42 (1st Cir.2011) (noting that under the “auto exception,” if “there is probable cause to believe a vehicle contains evidence of criminal activity, agents can search without a warrant any area of the vehicle in which the evidence may be found” (internal quotation marks omitted)). Even if the automobile exception didn’t apply though, the police made a “good faith error” because based on their “legal presence on [the] property, the probable cause known to them at the time, and the automobile exception, it was entirely reasonable for them to believe that the warrantless search of the Expedition was justified,” the district court concluded. See Illinois v. Krull, 480 U.S. 340, 348-49, 107 S.Ct. 1160, 94 L.Ed.2d 364 (1987) (recognizing that evidence resulting from a Fourth Amendment violation should only be suppressed “if it can be said that the law enforcement officer had knowledge, or may properly be charged with knowledge, that the search was unconstitutional under the Fourth Amendment” (internal quotation marks omitted)). The court did, however, exclude the search of the flower box, on the grounds that even though the police had probable cause, there were no exigent circumstances to justify searching there because Bernard had been arrested and the house was secure, rendering safety a non-issue. The court likewise excluded the fruits of the flower-box search (four rifles found under the dirt) because they dropped from a poisonous tree (the illegal search of the flower box), and no “good faith” exception applied. See Wong Sun v. United States, 371 U.S. 471, 484, 83 S.Ct. 407, 9 L.Ed.2d 441 (1963) (“[E]vidence seized during an unlawful search [can]not constitute proof against the victim of the search.”). As for Cruz-Ramos’s statement to the police, the court found that it could not be suppressed as fruit of the poisonous search because the search of the house was not poisonous (i.e., illegal). The court likewise rejected Cruz-Ramos’s argument that his statement was not given voluntarily, which he said violated the Fifth Amendment. No Probable Cause As we hinted at above, the focus of our analysis here is on whether the police had probable cause to search Cruz-Ramos’s home. Cruz-Ramos argues that since the sole basis of probable cause was the uncorroborated tip from an unknown informant, the police needed more than just his word to search without a warrant. “[W]e review de novo the district court’s conclusions of law, including its application of the law to the facts, its probable cause ... determination ], and the district court’s ultimate legal decision to grant or deny the motion to suppress.” United States v. Camacho, 661 F.3d 718, 724 (1st Cir.2011). In assessing whether there was probable cause for a search, “our task, like that of the ... district court, is simply to make a practical, common-sense decision whether, given all the circumstances, there is a fair probability that contraband or evidence of a crime will be found in a particular place.” United States v. McLellan, 792 F.3d 200, 208 (1st Cir.2015) (internal quotation marks and alterations omitted). We first provide a little background on the relevant law before diving into our analysis. The Fourth Amendment instructs that “no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.” U.S. Const, amend. IV. Based on this constitutional tenet, the law clearly establishes that even when police have a warrant to arrest someone, a search warrant is still “ordinarily required to enter the home of a third person to arrest an individual who is believed to be inside the home.” Fletcher v. Town of Clinton, 196 F.3d 41, 49 (1st Cir.1999). “Nevertheless, a warrantless entry into a person’s dwelling may be permitted” to effect an arrest, United States v. Samboy, 433 F.3d 154, 158 (1st Cir. 2005), so long as two conditions are met: one, the police had probable cause to enter the home, and two, “exigent circumstances” existed, like a fugitive’s threat to public safety. Hegarty v. Somerset Cty., 53 F.3d 1367, 1373-74 (1st Cir.1995). And probable cause only “exists when the totality of the circumstances suggests that there is a fair probability that contraband or evidence of a crime will be found in a particular place.” United States v. Gifford, 727 F.3d 92, 98 (1st Cir.2013) (internal quotation marks omitted). As was the case here, police often rely on tips from confidential informants to underlie probable cause. But the principle is long-standing that “[e]ven where a search warrant is obtained, the police must show a basis for the search beyond the mere fact of an assertion by an informer.” Recznik v. City of Lorain, 393 U.S. 166, 169, 89 S.Ct. 342, 21 L.Ed.2d 317 (1968). It follows then that “[a]t least as much is required to support a search without a warrant.” Id. at 169-70, 89 S.Ct. 342. Therefore, when, as here, “the primary basis for a probable cause determination is information provided by a confidential informant,” law enforcement must “provide some information from which a [court] can credit the informant’s credibility-” Gifford, 727 F.3d at 99. In other words, a “probable cause finding may be based on an informant’s tip so long as the probability of a lying or inaccurate informer has been sufficiently reduced.” Id. (internal quotation marks omitted). To help assess an informant’s reliability, we look to a “nonexhaustive” list of factors: (1) ... the probable veracity and basis of knowledge of persons supplying hearsay information; (2) whether an informant’s statements reflect first-hand knowledge; (3) whether some or all of the informant’s factual statements were corroborated wherever reasonable and practicable (e.g., through police surveillance); and (4) whether a law enforcement [officer] assessed, from his professional standpoint, experience, and expertise, the probable significance of the informant’s provided information. United States v. Tiem Trinh, 665 F.3d 1, 10 (1st Cir.2011) (citations, internal quotations marks, and alterations omitted). Applying these factors to the instant case, we find that there is simply no indication on this record that the police explored the Informant’s basis of knowledge for the information he relayed, or that the police bothered to corroborate any of the information that actually suggested that criminal activity was afoot at Cruz-Ramos’s home. Even if we were to agree with the district court that the information the Informant provided was detailed, we find that because the police did not sufficiently test the reliability of the detailed information, the denial of the motion to suppress cannot stand. Specifically, nothing in the district court’s factual findings “indicates the informant’s basis of knowledge,” such as whether the informant had firsthand knowledge of Bernard’s whereabouts (i.e., he had seen Bernard at the house), or just “heard about it as hearsay” or “through rumor.” See Gifford, 727 F.3d at 100; cf. Illinois v. Gates, 462 U.S. 213, 234, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983) (“[An informant’s] explicit and detailed description of alleged wrongdoing, along with a statement that the event was observed firsthand, entitles his tip to greater weight than might otherwise be the case.”). Notably, the only basis' Lieutenant Flores-Ortiz articulated for trusting the Informant was that because he “came from” the same housing project as Bernard, “[h]e could form a part of [Bernard’s] close-knit group.” That inference could implicate every resident in the complex, yet Lieutenant Flores-Ortiz apparently never bothered to ask the Informant whether he actually was part of Bernard’s crew. The Informant could have been relaying a rumor he overheard on the street, or even fabricating the information. It is also undisputed that the police here had no “past history with the informant to establish that informant’s credibility.” See Gifford, 727 F.3d at 100; cf. United States v. Dixon, 787 F.3d 55, 59 (1st Cir.2015) (that informant had given police “fruitful tips in the past” and police had met with the informant before “in person on several occasions” supported the informant’s reliability). Furthermore, while the district court credited the police for corroborating the Informant’s tips, our review shows that the only information the police actually corroborated before they entered the premises was the Informant’s (very general) outside description of the house. Indeed, all the police did here before entering the premises was drive by the home and confirm the readily apparent details the Informant described—that the home was in the gated community the Informant identified and had a flower box. But this kind of information, indeed, the kind that is immediately visible to anyone who passes the house, is not— without more—useful information when it comes to making a probable cause determination. True, “corroboration of even innocent activity reported in [a] tip may support a finding of probable cause,” at least when “[c]orroboration of apparently innocent activity can establish the reliability of the informant because the activity might come to appear suspicious in light of the initial tip.” Tiem Trinh, 665 F.3d at 12 (internal quotation marks omitted). But the information must be at least marginally useful in establishing that criminal activity is afoot. See Alabama v. White, 496 U.S. 325, 332, 110 S.Ct. 2412, 110 L.Ed.2d 301 (1990) (noting that it is “also important that ... ‘the anonymous tip contained a range of details relating not just to easily obtained facts and conditions existing at the time of the tip, but to future actions of third parties ordinarily not easily predicted.’ ” (quoting Gates, 462 U.S. at 245, 103 S.Ct. 2317)). Here, the police did not corroborate any of the information that might actually have suggested suspicious activity. For instance, one could find it curious to see multiple adults (at least one the Informant even identified by name) coming in and out of a single-family home. Or perhaps if the police had staked out the house, they might have seen someone protectively guarding or manipulating the flower box in an unusual way. Cf. id. at 11 (police conducted surveillance to corroborate much of the informant’s information, including the fact that the informant had, multiple times, been in and out of the house where the purported drug operation was going down). In sum, we find that the police did not do enough to confirm the unknown Informant’s story such that probable cause could issue. Our outcome should be no surprise, given our precedent. In addition to the test we laid out in Tiem Trinh, we have emphasized on multiple occasions that an informant’s reliability must be vetted. For instance, in United States v. Jordan, we carefully weighed the police’s efforts to corroborate a hearsay tip, and specifically noted some of the “various means” by which an informant could be corroborated, such as “direct surveillance or circumstantial evidence,” “vouchsaffing]” by a “highly experienced law enforcement officer,” “independent corroboration” (i.e., conducting controlled drug buys), and most particularly, the informant’s history of providing “reliable information and investigative assistance to the police in the past.” 999 F.2d 11, 13-14 (1st Cir.1993). We found that on balance, all of these efforts on the part of the police sufficed to corroborate the informant’s tip. In Dixon, the police officer took similar measure, meeting with the informant face-to-face “on several occasions,” “independently corroborat[ing] facts,” including not only “innocent facts” like the defendant’s phone number and car-type, but also by conducting controlled drug buys that “were carefully monitored and regulated to minimize the chance that the [informant] could have falsely implicated” the defendant. 787 F.3d at 59. Further, the informant in that case also had given “fruitful tips in the past.” Id. In contrast, anyone driving by Cruz-Ramos’s home could parlay the generic description the Informant gave, and confirming only those innocuous details is not, on its own, sufficient to corroborate a tip from an unknown confidential informant. The Informant did not even say that the house was the only one in the area with a flower box, meaning that the flower box’s existence did not make for a distinguishing characteristic. Given the lack of other indicia of the Informant’s reliability, the police had an obligation to corroborate something of the tip before entering Cruz-Ramos’s home without a warrant. See Recznik, 393 U.S. at 169, 89 S.Ct. 342 (finding that police did not have probable cause to enter a home when no “effort was made to show that either the petitioner or the apartment was at that time connected with” criminal activity, and the police did not “even attempt to establish that the informers were reliable”). In sum, there was no probable cause to search Cruz-Ramos’s home. Cruz-Ramos further asserts that the search of his car was also illegal for lack of probable cause. As we discussed above, the Informant’s tip was not sufficiently reliable on its own, and we agree with Cruz-Ramos that the same reasoning extends to the search of the Expedition. See United States v. Dickerson, 514 F.3d 60, 66 (1st Cir.2008) (noting that police may only conduct “a warrantless search of a car if there is probable cause to believe” the car has “contraband or evidence of a crime” (emphasis added)). Contrary to the district court’s decision, we conclude that the initial entry into the home was illegal, and so the police could not form probable cause from what illicit activity they observed once they entered the home. See Silverthorne Lumber Co. v. United States, 251 U.S. 385, 392, 40 S.Ct. 182, 64 L.Ed. 319 (1920) (“The essence of a provision forbidding the acquisition of evidence in a certain way is that not merely evidence so acquired shall not be used before the Court but that it shall not be used at all.”). Thus, there was no basis for probable cause to search the Expedition. For the same reason, the so-called “automobile exception” to the Fourth Amendment does nothing to save the search of Cruz-Ramos’s car (assuming the exception even applies to a car parked within the curtilage of a defendant’s home, as was the case here). See Coolidge v. New Hampshire, 403 U.S. 443, 460-62, 91 S.Ct. 2022, 29 L.Ed.2d 564 (1971). Sure, “the expectation of privacy with respect to one’s automobile is significantly less than that relating to one’s home,” such that “warrantless examinations of automobiles have been upheld in circumstances in which a search of a home ... would not.” South Dakota v. Opperman, 428 U.S. 364, 367, 96 S.Ct. 3092, 49 L.Ed.2d 1000 (1976). However, police still need “probable cause to believe that the automobile contains contraband” before conducting a warrant-less search. United States v. Silva, 742 F.3d 1, 7 (1st Cir.2014). As with a home-search, in this context “[p]robable cause exists when the facts and circumstances as to which police have reasonably trushvorthy information are sufficient to warrant a person of reasonable caution in the belief that evidence of a crime will be found.” Id. (internal quotation marks omitted and emphasis added). As we discussed, the police did not probe the Informant’s basis for his claims that weapons and drugs were in the car and therefore had no reasonable basis for believing the Informant’s tip, such that probable cause could issue on the tip alone. One final point on probable cause — that the police actually did end up finding guns, drugs, and, of course, Bernard in Cruz-Ramos’s home cannot enter our calculus, as “[a] search unlawful at its inception may [not] be validated by what it turns up.” United States v. Mercedes-De La Cruz, 787 F.3d 61, 69 (1st Cir.2015) (quoting Wong Sun, 371 U.S. at 484, 83 S.Ct. 407 (internal quotation marks omitted)). Based on these facts, we conclude that there was no probable cause to enter Cruz-Ramos’s home or car. Thus, while we certainly understand (though we do not address whether) exigency may have been a legitimate concern here because of Bernard’s status as a dangerous fugitive, the Constitution does not permit the police to forego a search warrant in situations like this based on exigency alone. Rather, as we have discussed, they also need probable cause. See Hegarty, 53 F.3d at 1373-74. The Seized Physical Evidence We must next consider whether the evidence seized as a result of the illegal search should also have been suppressed at trial. It is well established under the “exclusionary rule” that generally, “evidence seized during an unlawful search [ean]not constitute proof against the victim of the search.” Wong Sun, 371 U.S. at 484, 83 S.Ct. 407. That is, the government “may make no use of evidence illegally seized.” Mapp v. Ohio, 367 U.S. 643, 657, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961). It’s clear, then, that per the plain language of the exclusionary rule, the physical evidence seized during the illegal search of Cruz-Ramos’s home (including the car and flower box), should have been suppressed. The district court said as much when