In United States v. Hatten (U.S. Court of Appeals Eighth Circuit, 1995), the court held to be admissible as evidence a handgun and marijuana seized from a vehicle by an officer who observed them through the vehicle window with the aid of a flashlight. The vehicle was parked in a lot patrolled by a police officer "moonlighting" as a security officer. James Hatten, the driver, was sitting in the vehicle with a male companion. The court held that the officer complied with the elements of the plain-view doctrine. At issue was the officer's prior justification to look in the vehicle. The court held that as a security officer responsible for securing the parking lot, the officer had a right to be in close proximity to the vehicle so as to observe what was inside. Further, the court held that statements made by Hatten while in police custody were not subject to Miranda warnings, because the statements were made voluntarily and not within the context of a police interrogation. The section on legal commentary advises that the U.S. Supreme Court has held that the mere fact that a magistrate has issued a warrant (arrest or search) does not protect the officer who applied for the warrant if the warrant is obviously defective. The concluding section presents the circumstances and lessons of an incident in which a police officer failed to confiscate a gun hidden in the pillow of a wheelchair used by the suspect, based upon the officer's belief that the pillow had been searched by a security officer at the scene.