United States v. Clifton Campbell, 677 F. App'x 838

Clifton Deron Campbell was charged under 18 U.S.C. § 922(g)(1) for possession of a firearm and ammunition as a convicted felon.
Police arrested Campbell just outside a residence pursuant to an arrest warrant.
Officers found marijuana, empty baggies, and digital scales on Campbell, and included those facts in a search-warrant affidavit.
The affidavit did not strongly tie Campbell to the residence; officers, however, had additional undisclosed facts suggesting he lived there (surveillance, his car regularly parked there, his girlfriend rented the home).
The district court denied Campbell’s motion to suppress, concluding that even if the affidavit lacked probable cause, the Leon good-faith exception applied. Campbell pleaded guilty and appealed the denial of the suppression motion.
The Fourth Circuit affirmed, holding the good-faith exception justified denial of suppression given all circumstances and undisclosed but known facts to officers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the affidavit established probable cause tying Campbell to the residence	Affidavit failed to adequately connect Campbell to the home; thus the search warrant lacked probable cause	Officers had observations and evidence (drugs on Campbell) supporting a search, and officers also had undisclosed surveillance-based facts linking Campbell to the residence	Court did not decide probable cause; proceeded to good-faith analysis and upheld the search under the good-faith exception
Whether the good-faith exception applies despite a possibly deficient affidavit	Good-faith exception inapplicable because affidavit so lacking in indicia of probable cause that belief in its existence was unreasonable	Good-faith exception applies because a reasonably well-trained officer, considering both affidavit contents and unpresented facts known to officers, would have believed the search lawful	Good-faith exception applies; suppression not required

United States v. Andrews, 577 F.3d 231 (4th Cir.) (general rule that evidence from a Fourth Amendment violation is inadmissible)
United States v. Lalor, 996 F.2d 1578 (4th Cir.) (good-faith exception applied unless officers were dishonest, reckless, or lacked objectively reasonable belief in probable cause)
United States v. Leon, 468 U.S. 897 (Sup. Ct.) (warrant issued by magistrate ordinarily establishes officer good faith)
United States v. Hyppolite, 65 F.3d 1151 (4th Cir.) (good-faith exception inapplicable if affidavit so lacking in indicia of probable cause that belief was entirely unreasonable)
United States v. McKenzie-Gude, 671 F.3d 452 (4th Cir.) (courts may consider uncontroverted facts known to officers but not disclosed to magistrate in good-faith analysis)
United States v. Williams, 740 F.3d 308 (4th Cir.) (standard of review: factual findings for clear error, legal conclusions de novo)
United States v. Grossman, 400 F.3d 212 (4th Cir.) (when suppression denied, view evidence in light most favorable to Government)
United States v. Legg, 18 F.3d 240 (4th Cir.) (court may proceed directly to good-faith analysis without resolving probable cause)