United States v. Guzman-Batista
783 F.3d 930
1st Cir.2015Background
- On Oct. 9, 2012, PRPD Agent Héctor L. Rivera-Torres surveilled unit #A-8 and observed Luis A. Guzmán-Batista arrive on an ATV, enter #A-8 ~5 minutes, then exit, reposition a pistol from front to back waistband, and ride to a cream-colored house where he entered and did not reemerge. Rivera followed and later obtained a state search warrant for that house; the search recovered six 9mm bullets.
- Guzmán was under pretrial home-detention with an electronic monitoring bracelet (75–150 ft perimeter, six-minute grace period). Pretrial Services had no alert for Oct. 9, 2012; Guzmán’s file showed prior perimeter violations and manipulation attempts.
- Guzmán moved to suppress, arguing the warrant affidavit contained false statements because the monitoring system produced no alert, which (he said) made Rivera’s observation impossible; the magistrate granted a Franks hearing and issued an R&R recommending suppression, crediting the monitoring evidence and finding Rivera’s account “incredible.”
- The government requested a de novo hearing before the district court; the court heard live testimony (including Rivera, Pretrial Services, and distance/speed evidence) and credited Rivera’s testimony that Guzmán left his residence, displayed and moved a pistol, and entered the searched house, concluding there was probable cause for the warrant.
- Guzmán pled guilty conditionally, reserved the suppression issue, was sentenced, and timely appealed the denial of suppression. The First Circuit reviewed factual findings for clear error and affirmed, emphasizing deference to district-court credibility determinations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Franks challenge showed affidavit contained false statements necessary to probable cause | Guzmán: bracelet generated no alert on Oct. 9, so Rivera’s timeline is impossible; affidavit therefore false and warrant lacked probable cause | Government: Rivera’s timeline is plausible within the six-minute grace period; alternate explanations (prior alerts, manipulation) make the lack of an alert non-dispositive | Held: District court’s credibility finding for Rivera was not clearly erroneous; probable cause existed and suppression was properly denied |
| Standard of review for Franks factual findings | Guzmán: district court must not credit Rivera given objective monitoring evidence | Government: credibility determinations are for the district court and reviewed for clear error | Held: factual findings reviewed for clear error; absent objective contradiction, appellate court defers to district court credibility call |
Key Cases Cited
- Anderson v. City of Bessemer, 470 U.S. 564 (credibility challenges to factual findings are rarely clear error)
- United States v. Tzannos, 460 F.3d 128 (Franks-related factual findings reviewed for clear error)
- United States v. Henderson, 463 F.3d 27 (deference to district court credibility determinations)
- Rivera-Gómez v. de Castro, 900 F.2d 1 (once district court credits testimony, appellate reversal is unlikely)