United States v. Cassetti Brown, 567 F. App'x 272

On Aug. 11, 2010, Leesville officer Somers stopped Cassetti Brown for failing to yield; Somers smelled alcohol and observed an open container. Brown and a passenger (Cole) were in the Jeep.
While running a license check, Somers recalled a narcotics alert from agent Lopez identifying Brown as a subject of an ongoing drug investigation; Somers asked for consent to search the vehicle and, after initially refusing twice, Brown consented after about one minute.
Somers found one rock of crack cocaine (0.7 g) in the center console; later police found marijuana in the patrol car where Cole had sat.
Lopez prepared a one‑page affidavit the next morning and obtained a warrant to search Brown’s residence; officers conducted the search and seized approximately 90.6 grams of crack packaged in small blue zip bags and other indicia linking the home to Brown.
Brown moved to suppress evidence from both the vehicle search and the residence search; the district court denied both motions, Brown was convicted and sentenced, and he appealed.
The Fifth Circuit affirmed denial as to the vehicle search (stop and consent lawful) but reversed as to the residence search, holding the warrant affidavit was a “bare‑bones” submission and the Leon good‑faith exception did not apply; conviction vacated and case remanded.

Issue	Brown's Argument	Government's Argument	Held
1) Whether the traffic stop was unconstitutionally prolonged and whether consent to search the vehicle was voluntary	Stop was unlawfully prolonged after computer checks; consent was coerced by the extended detention	Officer lawfully extended the stop based on the collective knowledge (Lopez alert) and Brown voluntarily consented	Stop extension (~60 sec) was reasonable given officer’s personal observations + Lopez’s alert; consent found voluntary; vehicle evidence admissible
2) Whether the search warrant for Brown’s residence was supported by probable cause or salvageable under Leon’s good‑faith exception	Affidavit was insufficient (bare‑bones); warrantless search violated Fourth Amendment; suppression required	Magistrate issued warrant; officers relied on it in good faith	Affidavit lacked detail on informant reliability, nexus to residence, and contained misleading statements; affidavit was so lacking that good‑faith exception did not apply; residence evidence suppressed

United States v. Leon, 468 U.S. 897 (good‑faith exception to exclusionary rule for reasonable officer reliance on warrant)
Schneckloth v. Bustamonte, 412 U.S. 218 (consent voluntariness tested under totality of the circumstances)
Illinois v. Gates, 462 U.S. 213 (totality‑of‑the‑circumstances test for informant tips and probable cause)
United States v. Brigham, 382 F.3d 500 (5th Cir.) (reasonableness of brief stop extensions to obtain consent)
Hensley v. Williams, 469 U.S. 221 (officer may rely on other law‑enforcement bulletins/alerts under collective‑knowledge principles)