State v. Holden
60 A.3d 1110
| Del. | 2013Background
- State appeals a Superior Court suppression order granting Holden's motion, challenging the warrant affidavit's probable cause.
- Earlier, 12 pounds of marijuana were seized from Holden's car; suppression of that evidence led to nolle prosequi on charges.
- Two confidential informants provided tips that Holden sold drugs from a Newark house, detailing address, vehicle, and cohabitant.
- Police partially verified tips, including Holden's Newark residence and a white Chrysler; Pfeiffer was stopped with oxycodone shortly after leaving Holden's house.
- Pfeiffer's arrest prompted a magistrate to issue a search warrant; police found drugs in Holden and Lusby's home.
- Superior Court had ruled the warrant lacked probable cause; en banc this Court reversed and reinstated the suppression denial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a substantial basis for probable cause? | State argues affidavit, with informant tips corroborated by surveillance, supports probable cause. | Holden argues the tip details and lack of corroboration undermine probative value; totality fails. | Magistrate had substantial basis for probable cause; suppression reversed. |
| Should the reviewing court defer to the magistrate's probable cause determination? | State asserts great deference to magistrate findings and practical, commonsense assessment. | Holden contends deference should not excuse failure to show probable cause. | Deference applied; magistrate's totality-of-circumstances analysis supported probable cause. |
| Did corroboration of informants' tips, including Pfeiffer's possession, justify the inference of drug activity at Holden's home? | State emphasizes corroboration via Pfeiffer's oxycodone discovery and deception about origin. | Holden argues lack of direct drug deals or controlled buys weakens the nexus. | Totality of circumstances provided sufficient corroboration; nexus established. |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (probable cause tested by totality of the circumstances)
- U.S. v. Ventresca, 380 U.S. 102 (U.S. 1965) (affidavits tested with common-sense approach)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good faith reliance on warrants; deference to magistrates)
- Spinelli v. U.S., 393 U.S. 410 (U.S. 1969) (reliability-based informant standard (overruled in part by Gates))
- LeGrande v. State, 947 A.2d 1103 (Del. 2008) (Delaware standard for reviewing warrant affidavits and probable cause)
- Jones v. State, 28 A.3d 1046 (Del. 2011) (Delaware corroboration and informant reliability considerations)
- Lopez-Vazquez v. State, 956 A.2d 1280 (Del. 2008) (informant tip reliability and corroboration framework)
- Smith v. State, 887 A.2d 470 (Del. 2005) (Delaware standards on probable cause and corroboration)