State of Indiana v. Douglas E. Shipman, 2013 Ind. App. LEXIS 179

K.G., a 17-year-old, was in police custody for burglary and provided information implicating Shipman’s home in marijuana activity.
K.G. claimed he saw four one-pound bricks of marijuana at Shipman’s residence on June 22, 2010.
Trooper Staggs sought a search warrant based on K.G.’s statements; Judge R. Michael Cloud issued the warrant.
Police executed the warrant at Shipman’s home and charges were filed for dealing in marijuana and maintaining a common nuisance.
Shipman moved to suppress the evidence in June 2011; the trial court granted suppression on June 20, 2012 after a hearing.
The State appealed, arguing probable cause and good-faith exceptions; the appellate court reversed and remanded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause sufficiency for the warrant	Shipman argues the affidavit lacked probable cause.	Shipman argues statements were not sufficiently reliable to establish probable cause.	Probable cause existed; warrant valid.
Good-faith exception applicability	State asserts officers relied in good faith on the warrant.	Shipman contends lack of probable cause undermines good faith.	Good-faith exception applied; suppression not required.

Spillers v. State, 847 N.E.2d 949 (Ind. 2006) (probable cause based on informant reliability and penal-interest declarations; not automatic suppression)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith reliance on defective warrant may avert suppression)
Casady v. State, 934 N.E.2d 1181 (Ind. Ct. App. 2010) (probable-cause review limited to evidence before the magistrate)
Newby v. State, 701 N.E.2d 593 (Ind. Ct. App. 1998) (informant credibility not strictly required to corroborate penal-interest statements)
Houser v. State, 678 N.E.2d 95 (Ind. 1997) (informant credibility and penal-interest considerations)
Hensley v. State, 778 N.E.2d 484 (Ind. Ct. App. 2002) (limits on required legal research before obtaining warrants)