People of Michigan v. Christopher Michael Thomson, 371943

Defendant Christopher Michael Thomson was charged with possession of dangerous weapons and felony-firearm after police searched his home following a domestic incident.
The search occurred after defendant's wife, claiming assault and that defendant owned many firearms, called police; defendant allegedly brandished a weapon at responding officers.
Police secured a search warrant based on an affidavit detailing the domestic incident, the brandishing of a pistol, and information about firearms in the home.
The search produced firearms, including a fully automatic rifle and suppressors.
At trial, the defendant moved to suppress the evidence, arguing the warrant lacked probable cause. The trial court agreed but allowed the evidence under the good-faith exception.
The prosecution appealed the probable cause finding; the defendant appealed the application of the good-faith exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the search warrant supported by probable cause?	The facts linked the firearms to the alleged crime	Warrant lacked sufficient facts tying firearms to any crime	Warrant did have probable cause for firearms and related objects
Should the good-faith exception apply if the warrant lacked probable cause?	Officers reasonably relied on the warrant	Affidavit was so bare of probable cause that reliance was unreasonable	Good-faith exception applies; officers' reliance was not unreasonable
Was there probable cause to search and seize electronics?	Evidence might be found on electronic devices	No specific allegations involving electronics	No probable cause for electronics, but this part of warrant is severable

People v. Franklin, 500 Mich 92 (Michigan probable cause standard for warrants)
People v. Mullen, 282 Mich App 14 (Standard of review for probable cause in search warrants)
People v. Whitfield, 461 Mich 441 (Warrant affidavit does not need to prove a crime, only show a fair probability)
People v. Keller, 479 Mich 467 (Severability doctrine for overbroad search warrants)
People v. Goldston, 470 Mich 523 (Good-faith exception to the exclusionary rule adopted in Michigan)