People v. Manzo, 129 N.E.3d 1141

In June 2009 Officer Jeremy Harrison swore a complaint for a warrant to search Ruben Casillas, a black Ford Explorer, and the premises at 701 W. Marion St., Joliet — the residence of Jorge Manzo Jr. and Leticia Hernandez.
Harrison conducted three controlled buys of small amounts of cocaine from Casillas over 19 days; two buys occurred in the vicinity of 701 W. Marion. On one buy Casillas arrived in a vehicle registered to Hernandez at 701 W. Marion; on another officers observed Casillas exit 701 W. Marion and walk to the buy location.
The warrant sought cocaine, currency, drug paraphernalia, proof of residency/ID, and related items. The magistrate issued the warrant; search executed June 12, 2009. Seized from the home: 348 grams of cocaine, a handgun and ammunition, digital scale, plastic bags, and cash.
Manzo moved to quash/suppress arguing the affidavit lacked a nexus between Casillas’s off-site sales and Manzo’s home (no evidence Casillas lived at, sold from, or stored contraband at the residence). Trial court denied suppression; jury convicted Manzo of being a felon in possession of a weapon (acquitted on intent-to-deliver charge).
The appellate court affirmed (2–1). Illinois Supreme Court granted review and reversed: held the affidavit failed to establish probable cause as to the residence and also was a “bare-bones” affidavit such that the Leon good-faith exception did not save the search; suppression required and conviction reversed.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Manzo)	Held
Probable cause to search 701 W. Marion St.	Affidavit + reasonable inferences (vehicle registered to residence, Casillas seen leaving the residence and walking to a buy, buys near the residence) established a fair probability evidence would be at the house.	Affidavit lacked direct facts connecting Casillas’s sales to the residence — no allegation Casillas lived there, stored contraband there, or sold from there; mere presence or proximity is insufficient to create a nexus.	Held: No. The totality of the affidavit did not provide a substantial basis to infer a nexus between Casillas’s drug activity and Manzo’s home; warrant was unsupported by probable cause.
Applicability of Leon good-faith exception	Even if warrant insufficient, officers reasonably relied on a neutral magistrate’s warrant; good-faith exception applies.	Affidavit was “bare-bones” (conclusory, devoid of nexus) so no objectively reasonable officer could rely on it; exclusion required.	Held: No good faith. The affidavit was so lacking in indicia of probable cause that reliance was objectively unreasonable; exclusionary rule applies and the seized evidence must be suppressed.

Illinois v. Gates, 462 U.S. 213 (totality-of-circumstances standard for probable cause)
United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule)
Payton v. New York, 445 U.S. 573 (heightened protection for the home)
Kyllo v. United States, 533 U.S. 27 (home as core Fourth Amendment protection)
Zurcher v. Stanford Daily, 436 U.S. 547 (critical element is nexus between place and items sought)
People v. Tisler, 103 Ill. 2d 226 (Illinois follows federal probable-cause standards)
People v. McCarty, 223 Ill. 2d 109 (presumption of affidavit validity; mixed fact-law review on suppression)
Davis v. United States, 564 U.S. 229 (exclusionary rule’s deterrent purpose and costs)