United States v. A.C. Jackson, 784 F.3d 1227

On March 28, 2013, A.C. Jackson reported a .22 rifle stolen; deputies learned Jackson was a convicted felon and that a nephew (Bobby Joe Jackson) had taken the rifle after a dispute.
The nephew told officers he feared Jackson and said he had arranged with neighbor Bob Elledge to take the rifle for safety; he also reported another multi‑barreled firearm at Jackson’s residence.
Jackson denied having firearms in the home and refused a voluntary search; officers arrested him, took photos of the home, and the deputy prepared an affidavit for a search warrant.
The affidavit recited interviews with Jackson, the nephew, and Elledge, the deputy’s belief Jackson possessed other firearms, and that the deputy found Jackson’s initial theft report to be false; a prosecutor reviewed the affidavit and a circuit judge questioned the deputy and signed the warrant.
Execution of the warrant uncovered a Rossi multi‑barreled firearm and ammunition; Jackson later admitted buying the .22 rifle but denied ownership of the Rossi firearm.
Jackson moved to suppress the Rossi firearm, arguing the warrant lacked probable cause; the district court found no substantial basis for probable cause but admitted the evidence under the Leon good‑faith exception. Jackson appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant affidavit was so lacking in probable cause that evidence must be suppressed	Jackson: affidavit lacked sufficient indicia of probable cause and was objectively unreasonable	Government: affidavit contained corroborated firsthand statements and judge approved warrant; officers acted reasonably	Court: did not reach probable‑cause sufficiency because evidence admitted under Leon good‑faith exception
Whether Leon good‑faith exception applies	Jackson: affidavit so deficient (and containing false/misleading statement) that good faith is unreasonable	Government: deputy relied on interviews, corroboration, prosecutor review, and judge’s independent questioning; reliance was objectively reasonable	Court: Leon applies—officer’s reliance was objectively reasonable
Whether affidavit contained knowingly false or recklessly false statements	Jackson: statement that theft report was false was false or made with reckless disregard	Government: deputy reasonably believed report was not a theft based on interviews and context	Court: no showing of deliberate or reckless falsity; statement was reasonable inference
Whether issuing judge abandoned judicial role or failed meaningful review	Jackson: judge’s interaction with deputy insufficient to cure affidavit defects	Government: judge asked questions and engaged beyond affidavit before signing	Court: judge did not wholly abandon role; he made inquiries and issued warrant

United States v. Leon, 468 U.S. 897 (1984) (establishes good‑faith exception to exclusionary rule)
United States v. Proell, 485 F.3d 427 (8th Cir. 2007) (courts may consider Leon exception before probable‑cause analysis)
United States v. Houston, 665 F.3d 991 (8th Cir. 2012) (standard of review on suppression appeal)
United States v. Puckett, 466 F.3d 626 (8th Cir. 2006) (objective‑reasonableness inquiry for officers relying on warrants)
United States v. Fiorito, 640 F.3d 338 (8th Cir. 2011) (exclusionary rule and warrant requirements)