United States v. Erik McCoy, 905 F.3d 409

Cincinnati police investigated a tip that Erik McCoy and Derrick Heard sold marijuana from two adjacent Glenway Avenue stores and lived together at 10515 Hadley Road. The tipster claimed to have seen drugs and guns inside the Hadley Road home.
Officer Longworth surveilled the stores, observed heavy foot traffic, and confirmed McCoy and Brown had drug-trafficking records.
Heard was arrested in a Glenway Avenue store after exiting an employee-only area with two bags of marijuana; officers found scales, packaging materials, and gun accessories in the stores and mail addressed to McCoy.
Longworth obtained and executed a warrant to search 10515 Hadley Road; the search uncovered ~2,200 grams of heroin, marijuana, an electronic scale, ammunition, a handgun, and about $38,000 in cash.
The district court suppressed the Hadley Road evidence, holding the affidavit failed to connect the house to drug activity and rejecting the Leon good-faith exception; the government appealed.
The Sixth Circuit reversed, holding a reasonably well-trained officer could have relied on the warrant given corroborated informant information, Heard’s arrest at the suspected distribution site, the store’s contraband, and defendants’ records.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence from Hadley Road must be suppressed because the warrant affidavit lacked a nexus between the home and drug activity	Government: affidavit provided corroborated facts (informant tip, surveillance, Heard’s arrest with marijuana, contraband in stores, residency tie) supporting reasonable reliance	McCoy/Heard: affidavit failed to connect illegal activity to the residence; nexus insufficient for probable cause or good-faith reliance	Reversed suppression: Leon good-faith exception applies—affidavit had a minimally sufficient nexus and corroboration to make reliance reasonable
Whether the affidavit established probable cause or only supports good-faith reliance	Government: facts established ongoing distribution activity making it reasonable to infer contraband would be at home	Defendants: lacked particularized facts tying the residence to trafficking; single-site arrests insufficient for nexus	Court: affidavit may not have met "substantial basis" for probable cause, but satisfied the lower good-faith standard—officers’ reliance was objectively reasonable

United States v. Leon, 468 U.S. 897 (1984) (creates good-faith exception to exclusionary rule)
United States v. White, 874 F.3d 490 (6th Cir. 2017) (requires a minimally sufficient nexus for Leon review; read affidavit holistically)
United States v. Brown, 828 F.3d 375 (6th Cir. 2016) (nexus typically requires facts showing residence used in trafficking)
United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (permissible inferences can save an otherwise insufficient affidavit under Leon)
United States v. Frazier, 423 F.3d 526 (6th Cir. 2005) (single instance of dealing away from home insufficient to tie residence to trafficking)
United States v. Kenny, 505 F.3d 458 (6th Cir. 2007) (arrest near a drug base and corroborated informant tied to a search of the defendant’s home)
United States v. McPhearson, 469 F.3d 518 (6th Cir. 2006) (Leon may apply when officers reasonably rely on magistrate’s determination)
United States v. Williams, 544 F.3d 683 (6th Cir. 2008) (it is reasonable to infer criminals store evidence of crimes in their homes)
United States v. Newton, 389 F.3d 631 (6th Cir. 2004) (continual, ongoing trafficking can establish probable cause to search dealer’s residence)
United States v. Gunter, 551 F.3d 472 (6th Cir. 2009) (repetitive large-quantity sales support inference of ongoing trafficking and nexus to residence)