State of Indiana v. Christopher J. Basinger (mem. dec.)
59A05-1601-CR-195
| Ind. Ct. App. | Oct 12, 2016Background
- Police obtained and executed a search warrant for Christopher J. Basinger’s home after Detective Shane Staggs submitted an affidavit alleging evidence of methamphetamine use and possession.
- The affidavit was based primarily on statements from Heather Basinger (the affiant’s ex-wife per affidavit) who reported finding burnt aluminum foil and a glass-like substance in a coffee-table drawer and that Chris reacted angrily and warned she could send him to prison.
- Detective Staggs noted Heather showed a text referencing being “minus the drugs and alcohol” and that Basinger’s name had appeared in other meth investigations; Staggs also relied on his training linking aluminum foil to meth use.
- Officers seized firearms, foil with burn residue, a digital scale, and a white powder that field-tested positive for methamphetamine.
- Basinger moved to suppress the evidence, arguing the affidavit lacked sufficient indicia of probable cause; the trial court granted the motion, the State dismissed the charge, and appealed.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Basinger) | Held |
|---|---|---|---|
| Validity of warrant: whether affidavit provided probable cause | Heather’s firsthand account and corroborating details (text message, prior investigations, officer training) established a fair probability of finding meth evidence | Affidavit relied on uncorroborated hearsay and did not establish informant credibility or sufficient corroboration | Warrant invalid: affidavit lacked sufficient indicia of probable cause |
| Applicability of hearsay/corroboration standards | Heather’s firsthand statements carry weight; some corroboration exists via text and prior-investigation knowledge | Hearsay requires either demonstrable informant credibility or corroboration of the tip; affidavit lacked both | Hearsay insufficient: no reliable basis for Heather’s credibility and corroboration was inadequate |
| Good-faith exception to exclusionary rule | Officers relied on a magistrate-approved warrant in good faith; evidence should be admissible under Leon | Affidavit was so deficient that objectively reasonable reliance was not possible; detective should have known statutory requirements | Good-faith exception inapplicable: reliance on warrant was not objectively reasonable |
| Effect of post-search facts or contradictions in affidavit | State implied additional facts justify affidavit | Basinger presented contrary evidence (e.g., Heather’s marital status and deposition denying seeing foil) showing unreliability | Court did not consider post-search facts for probable-cause review; noted contradictions support need for credibility/corroboration but ruling rests on affidavit’s face |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (establishes totality-of-the-circumstances test for probable cause)
- United States v. Leon, 468 U.S. 897 (creates objective good-faith exception to exclusionary rule)
- Jaggers v. State, 687 N.E.2d 180 (discusses magistrate’s role and informant reliability indicators in Indiana)
- Spillers v. State, 847 N.E.2d 949 (lists ways to establish hearsay trustworthiness for probable cause)
- Buford v. State, 40 N.E.3d 911 (holds uncorroborated hearsay from unknown-credibility sources cannot alone support probable cause)