United States v. Jarmell Mayweather, 993 F.3d 1035

A confidential reliable informant (CRI) told law enforcement in 2016 that Mayweather sold large quantities of cocaine and drove a black Cadillac Escalade; surveillance and registration records associated the Escalade and a 19th Street residence with Mayweather.
Law enforcement arranged controlled buys: a February 2016 attempt (allegedly no money exchanged) and a March 2016 controlled buy that officers observed; after the March buy, officers saw Mayweather meet a suspected dealer who then drove him to the 19th Street address.
Deputy McLouden’s affidavit for search warrants recited the CRI’s prior reliability, the controlled-buy details, surveillance observations (vehicle coming and going at all hours), and routine drug-trafficking indicia based on his training (scales, packaging, electronic devices, ledgers, cash).
Warrants issued; searches of the residence and vehicle yielded substantial quantities of crack and cocaine and drug paraphernalia.
Mayweather moved to suppress (arguing no nexus between residence and criminal activity and Leon inapplicable) and later sought a Franks hearing alleging false statements/omissions in the affidavit (controlled-buy timing, CRI reliability, omitted GPS tracking). District court denied suppression and denied a Franks hearing; jury convicted Mayweather and sentence imposed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Motion to suppress: probable cause/nexus and Leon good-faith exception	Affidavit failed to establish a nexus between criminal activity and Mayweather’s residence; evidence must be suppressed because officer’s reliance was entirely unreasonable	Affidavit supplied enough indicia (CRI info, surveillance, return to residence after buy) and, even if nexus weak, executing officer reasonably relied on the magistrate’s warrant under Leon	Affirmed. Even if nexus were inadequate, the Leon good-faith exception applied because a reasonable officer could infer a dealer would store evidence at home and reliance on the warrant was objectively reasonable
Motion for Franks hearing (false statements & omissions)	McLouden knowingly or recklessly misstated that a cash-controlled buy occurred in March 2016, mischaracterized the CRI’s reliability, and omitted use of a GPS tracker—warranting an evidentiary Franks hearing	Mayweather failed to make the required substantial preliminary showing; the buy-form annotations and trial testimony do not establish deliberate falsehoods; CRI reliability assertions not shown false; GPS claim was untimely/waived	Affirmed. No substantial preliminary showing of deliberate falsehood or recklessness as to the buy or CRI reliability; GPS-tracking omission was waived for untimeliness; other alleged misstatements/omissions were immaterial

United States v. Leon, 468 U.S. 897 (1984) (establishes the good-faith exception to the exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause assessed under totality-of-the-circumstances ‘‘fair probability’’ standard)
Franks v. Delaware, 438 U.S. 154 (1978) (defendant entitled to hearing only after substantial preliminary showing of deliberate falsehood or reckless omission that was necessary to probable cause)
United States v. Moya, 690 F.3d 944 (8th Cir. 2012) (applies Leon when affidavit shows defendant distributing drugs in area—reasonable to infer evidence at residence)
United States v. Carpenter, 341 F.3d 666 (8th Cir. 2003) (Leon applies where common-sense inferences justify finding evidence at residence despite weak nexus)
United States v. Ross, 487 F.3d 1120 (8th Cir. 2007) (good-faith application where affidavit tied transactions to suspect and vehicle; multiple judges found sufficient indicia)
United States v. El-Alamin, 574 F.3d 915 (8th Cir. 2009) (Franks substantiality requirement and standards for challenging warrant statements)
United States v. Luloff, 15 F.3d 763 (8th Cir. 1994) (officer’s experience-based averments can support inference that traffickers keep records/evidence at home)
United States v. Carnahan, 684 F.3d 732 (8th Cir. 2012) (timeliness and waiver principles for Franks claims)