United States v. Harvey Robinson, 724 F.3d 878

Police obtained a warrant based on an anonymous informant ("John/Jane Doe") who said he bought marijuana from "Tookie" at 1453 S. Springfield and identified defendant Harvey Robinson from police photos.
Officers executed the warrant at about 6:00 a.m.; they found <2 grams of marijuana and a loaded .44-caliber revolver on a laundry basket by the front door. Robinson was asleep on a sofa.
Sergeant Blas testified Robinson twice admitted the gun was his: once at the scene after Miranda warnings and again at the station during interrogation by Officers Elizondo and Moore; Robinson denied making such statements.
Robinson moved to suppress the gun (challenging probable cause and seeking a Franks hearing); the district court denied suppression based on the Leon good-faith exception and denied a Franks hearing.
At trial Robinson stipulated to a prior felony conviction; the agreed written jury instruction limited that evidence to proving the element of prior conviction, but the court omitted the limiting sentence when reading instructions aloud and refused to recall the jury to correct it.
The jury convicted Robinson of being a felon in possession (18 U.S.C. § 922(g)(1)); on appeal the Seventh Circuit affirmed the warrant rulings but reversed and remanded for a new trial because the omitted oral limiting instruction was prejudicial.

Issue	Robinson's Argument	Government's Argument	Held
Probable cause for warrant	Warrant lacked sufficient corroboration of anonymous informant; identification procedure was flawed	Affidavit contained detailed, recent, firsthand statements and informant appeared before magistrate; minimal corroboration sufficed	Court assumed arguable probable cause but upheld admission under Leon good-faith exception
Franks hearing request	Police acted recklessly in relying on informant; Robinson submitted declarations contradicting informant	Police lacked obvious reason to doubt informant; no substantial showing of deliberate or reckless falsehood	Denial of Franks hearing affirmed (no clear error)
Jury instruction on prior felony	Omission of limiting sentence in oral instruction risked juror inference that prior conviction showed propensity to possess a gun	Written instructions were correct; jurors received full set and were told to reread them	Error: omission rendered oral instruction inaccurate and could have substantially influenced jury; not harmless; conviction vacated
Harmless-error analysis	The case was close; defense attacked officers’ credibility and jury deliberated nearly 11 hours — risk the error was outcome-determinative	Government argued strong officer testimony (two confessions and discovery admission) made error harmless	Court held government failed to prove beyond reasonable doubt the error was harmless; reversed and remanded for new trial

United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (totality-of-the-circumstances test for informant tips and probable cause)
Franks v. Delaware, 438 U.S. 154 (right to hearing if affidavit contains intentional or reckless falsehoods)
Kotteakos v. United States, 328 U.S. 750 (harmless-error standard focused on whether error substantially influenced jury)
Michelson v. United States, 335 U.S. 469 (prejudice from introducing prior convictions)
Neder v. United States, 527 U.S. 1 (limitations on appellate courts substituting their judgment for the jury)
United States v. Carson, 582 F.3d 827 (Seventh Circuit standard for magistrate deference in probable-cause review)
United States v. Miller, 673 F.3d 688 (Seventh Circuit application of Leon.good-faith analysis)