United States v. Chatmon
1:17-cr-00246
| W.D.N.Y. | Aug 29, 2018Background
- On May 15, 2017 Jamestown officers stopped Demario T. Chatmon while he was lawfully driving; he committed no traffic violation and was detained and transported to police custody where a small bag of suspected cocaine was recovered from his shoe.
- Later that day detectives sought and obtained a search warrant for Chatmon’s Apartment 2 (19 South Work Street) based principally on a confidential informant (CI) statement presented in camera to Judge LaMancuso.
- The warrant application and the CI’s in-court testimony contained material inconsistencies (amount of cocaine observed, identity of the person known as “Shawn,” and absence of observed paraphernalia), and portions of the judge’s off-the-record questioning were not recorded.
- Judge LaMancuso issued the warrant after a short in-camera exam; the warrant authorized broad seizure (cocaine, any controlled substances, scales, packaging, money, safes, etc.). The warrant was executed shortly after 2:00 p.m. the same day.
- The magistrate judge reviewing the motions concluded the warrant lacked a substantial basis for probable cause because of the informant’s incentives to fabricate, unexplored inconsistencies, off-the-record proceedings in violation of state procedure, and the warrant’s overbroad language.
- The court held the traffic stop invalid (no reasonable suspicion) and found no probable cause for the arrest or the apartment search; a suppression hearing was ordered to resolve whether the good-faith/Leon exception applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of search warrant for Apt. 2 (probable cause) | Warrant supported by CI and detective corroboration; magistrate’s finding deserves deference | CI was unreliable, contradictions unaddressed, off-record judge questioning, overbroad warrant | Warrant invalid: magistrate lacked substantial basis for probable cause |
| Lawfulness of traffic stop/detention | Stop justified because officers had the same information later presented to magistrate | Chatmon was stopped with no traffic violation and no reasonable suspicion | Stop invalid for lack of reasonable suspicion |
| Applicability of good-faith/Leon exception (whether suppression is required) | Officers acted in objectively reasonable reliance on magistrate-issued warrant | Warrant was so lacking and officers were culpable such that exclusion should apply | Hearing ordered to determine whether good-faith exception applies; suppression not decided yet |
| Need for evidentiary hearing / scope | Government contends magistrate’s probable-cause finding is dispositive and reliance was reasonable | Defense seeks suppression; requests Franks hearing was rendered moot pending Leon analysis | Court scheduled hearing to examine police conduct and objective reasonableness; Franks request denied as moot |
Key Cases Cited
- Illinois v. Gates, 462 U.S. 213 (probable cause is reviewed under the totality of the circumstances; magistrate’s determination entitled to deference)
- United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule when officers reasonably rely on a warrant)
- Herring v. United States, 555 U.S. 135 (limits on exclusionary rule where officer negligence, not deliberate misconduct, occurs)
- Ventresca v. New York, 380 U.S. 102 (affidavits must provide a substantial basis for magistrate’s probable-cause determination)
- United States v. Julius, 610 F.3d 60 (2d Cir.) (remand to consider whether deterrent effect of exclusion outweighs its costs)
- United States v. Clark, 638 F.3d 89 (2d Cir.) (government bears burden to show objective reasonableness of officers’ reliance on an invalid warrant)