United States v. Christopher Houghton, 20-1535

AMJ, recently released from jail, was stopped riding a moped with a stolen registration sticker and a pneumatic pistol with its orange tip removed; he told police Houghton had given him the moped and volunteered information about Houghton’s criminal activity.
AMJ said he had lived in Houghton’s shed, returned there after release, and observed Houghton obtain specific tools (brands/types), a mini‑bike frame, and other items; he identified addresses Houghton allegedly stole from and said Houghton unloaded tools and texted photos at about 1:30 a.m.
Police corroborated part of AMJ’s tip (owner confirmed a shed door propped open and missing lock at one identified address) and surveilled JF’s residence, observing Houghton there and later leave with a trailer.
Detective Lo’s affidavit to a magistrate incorporated AMJ’s detailed statements, corroboration, and the officer’s training/experience; a warrant issued and the executed search recovered a Snap‑On tool, a pipe bomb, and ammunition.
Houghton was federally indicted; the district court suppressed the evidence, finding the affidavit lacked probable cause and that the good‑faith exception did not apply. The government appealed.
The Sixth Circuit reversed suppression, holding the good‑faith exception applied even if the affidavit might not establish probable cause.

Issue	Houghton’s Argument	Government’s Argument	Held
Whether the affidavit established probable cause to search Houghton’s residence	Affidavit insufficient: informant’s credibility not established and corroboration was inadequate	AMJ was a named informant with recent, detailed, firsthand knowledge corroborated in part by police surveillance and confirmation of a shed	District court found no probable cause, but the Sixth Circuit did not decide probable cause definitively (resolved case on good‑faith grounds)
Whether the Leon good‑faith exception bars suppression	No: affidavit was effectively "bare bones"; a reasonable officer/magistrate would not rely on it	Yes: affidavit contained factual details, corroboration, and a nexus sufficient for objectively reasonable reliance	Sixth Circuit held the good‑faith exception applies; reversed suppression and remanded

United States v. Leon, 468 U.S. 897 (1984) (establishes good‑faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (1983) (totality‑of‑the‑circumstances test for probable cause)
United States v. Karo, 468 U.S. 705 (1984) (warrantless search presumptively unreasonable)
Illinois v. Krull, 480 U.S. 340 (1987) (limitations on exclusionary rule)
United States v. White, 874 F.3d 490 (6th Cir. 2017) (good‑faith and "bare‑bones" affidavit doctrine in Sixth Circuit)
United States v. Hines, 885 F.3d 919 (6th Cir. 2018) (definition of bare‑bones affidavit)
United States v. Woosley, 361 F.3d 924 (6th Cir. 2004) (magistrate’s independent determination and commonsense review)
Nathanson v. United States, 290 U.S. 41 (1933) (classic bare‑bones affidavit example)
United States v. Christian, 925 F.3d 305 (6th Cir. 2019) (informant reliability and corroboration as parts of totality analysis)
District of Columbia v. Wesby, 138 S. Ct. 577 (2018) (whole‑of‑the‑circumstances approach to probable cause and reasonable belief)