United States v. James Dutton, 24-5200

James Dutton was investigated for methamphetamine distribution from late 2020 to early 2021.
Police obtained a search warrant for Dutton's residence based on a confidential informant's (CI) recent tip and the affiant officer's experience.
The search uncovered about 50 grams of methamphetamine and a firearm; Dutton made incriminating admissions.
Dutton was indicted for conspiracy and possession with intent to distribute methamphetamine.
He moved to suppress evidence for lack of probable cause and for a Franks hearing alleging misstatements or omissions in the warrant affidavit.
After his motions were denied, Dutton pleaded guilty but reserved his appellate rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for search warrant	Affidavit lacked specific, non-stale evidence; CI unreliable	Affidavit established recent observation by reliable CI	Warrant valid; motion to suppress denied
Need for Franks hearing	Brewer (affiant) included false or misleading affidavit statements	No substantial evidence of reckless or intentional falsehood	No Franks hearing required; denial affirmed

United States v. Frechette, 583 F.3d 374 (6th Cir. 2009) (defines probable cause for search warrants)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause assessed under totality of the circumstances)
Franks v. Delaware, 438 U.S. 154 (1978) (sets standard for challenging search warrant affidavits)
United States v. Greene, 250 F.3d 471 (6th Cir. 2001) (reviewing substantial basis for probable cause)
United States v. Moore, 661 F.3d 309 (6th Cir. 2011) (upholding warrant based on recent CI observations)
United States v. Perry, 864 F.3d 412 (6th Cir. 2017) (stale information and probable cause)
United States v. McCraven, 401 F.3d 693 (6th Cir. 2005) (informant reliability in warrant affidavits)