State of Tennessee v. Rodney Paul Starnes, II, W2016-02491-CCA-R3-CD

Rodney Paul Starnes was indicted for possession with intent to sell synthetic cannabinoids after police obtained a search warrant for his residence at 55 Kari Circle.
Affidavit relied on a Confidential Source (CS) who said CS had previously bought synthetic cannabinoids from Starnes and identified Starnes as a known dealer at that address.
Police conducted two surveillance details after neighbor complaints; they observed hand-to-hand package transfers at ~3:30 p.m. on two occasions and identified vehicles linked to Starnes's relatives.
On November 12, officers stopped a vehicle observed leaving the residence; a passenger, Felicia Brooks (Starnes’s girlfriend), consented to a search and admitted Starnes sold synthetic cannabinoids and had delivered the observed package; marijuana was found in the vehicle.
While awaiting Starnes, officers spoke to Jamie Bryson (sister-in-law), who said she and her husband obtained synthetic cannabinoids from Starnes about a month earlier.
The trial court granted Starnes’s motion to suppress, finding the affidavit failed to meet the then-controlling Aguilar–Spinelli/Jacumin requirements; the State appealed and the Court of Criminal Appeals reversed after considering State v. Tuttle.

Issue	State's Argument	Starnes's Argument	Held
Whether affidavit established probable cause for a search warrant	Affidavit taken as whole showed corroboration and provided informant basis and veracity; police observations and admissions corroborated CS	Affidavit lacked informant’s basis of knowledge and reliability under Aguilar–Spinelli/Jacumin; was "bare-bones"	Reversed trial court: under totality-of-circumstances (Tuttle/Gates), affidavit provided substantial basis for probable cause
Whether Jacumin (Aguilar–Spinelli) still controls	State: affidavit sufficient under modern totality approach	Starnes: Jacumin required two-prong showing which affidavit failed to meet	Court applied Tuttle (overruling Jacumin) and analyzed totality; informant’s basis and veracity remain relevant but not rigidly separate; affidavit sufficient

State v. Jacumin, 778 S.W.2d 430 (Tenn. 1989) (adopted Aguilar–Spinelli two-prong test under Tennessee Constitution)
State v. Tuttle, 515 S.W.3d 282 (Tenn. 2017) (abrogated Jacumin and adopted Gates totality-of-the-circumstances approach)
Aguilar v. Texas, 378 U.S. 108 (1964) (one of the original two-pronged informant tests)
Spinelli v. United States, 393 U.S. 410 (1969) (paired with Aguilar to form the two-prong test)
Illinois v. Gates, 462 U.S. 213 (1983) (established the totality-of-the-circumstances standard for informant-based probable cause)
State v. Moon, 841 S.W.2d 336 (Tenn. Crim. App. 1992) (explained basis-of-knowledge and veracity prongs under Tennessee precedent)