106 F.4th 568
6th Cir.2024Background
- Shelby County officers, acting on a confidential informant's tip and evidence from a controlled drug buy, obtained a search warrant for Corey Neal’s residence at 873 Paradise Drive in Cordova, Tennessee.
- Officers linked Neal to drug trafficking and confirmed his residency through surveillance and vehicle registration records.
- During the search, officers found three firearms and nearly 400 grams of marijuana, resulting in federal charges for marijuana possession with intent to distribute and possession of firearms as a felon.
- Neal moved to suppress the evidence, arguing that the warrant affidavit lacked probable cause. The district court agreed probable cause was lacking but applied the good faith exception, denying the suppression motion.
- Neal pled guilty to the felon-in-possession charge but reserved his right to appeal the suppression ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the search warrant affidavit lacking in probable cause and therefore invalid? | Neal argued there was no sufficient nexus between the alleged criminal activity and his residence. | The government argued the affidavit had at least a minimal connection sufficient for the search. | Court agreed probable cause was lacking but focused on good faith exception. |
| Should the good faith exception apply to uphold the search despite lack of probable cause? | Neal contended the affidavit was so deficient it could not be relied on in good faith. | The government argued the affidavit established at least a minimally sufficient nexus. | Court held the good faith exception applied; suppression was not warranted. |
Key Cases Cited
- United States v. Leon, 468 U.S. 897 (exclusionary rule does not apply if officers rely on a warrant in objectively reasonable good faith)
- Illinois v. Gates, 462 U.S. 213 (probable cause exists when there is a fair probability that evidence will be found in a particular place)
- Davis v. United States, 564 U.S. 229 (exclusionary rule’s purpose is to deter police misconduct; only applies where there’s appreciable deterrent effect)
- United States v. Van Shutters, 163 F.3d 331 (Sixth Circuit precedent on probable cause nexus between place searched and evidence sought)
- United States v. Carpenter, 360 F.3d 591 (defining "bare-bones affidavits" and the minimal nexus standard required)
- Weeks v. United States, 232 U.S. 383 (originated federal exclusionary rule)
- Mapp v. Ohio, 367 U.S. 643 (applied exclusionary rule to states via Fourteenth Amendment)