United States v. Johnson, 867 F.3d 737

ATF agents, investigating informant Loren Coleman (indicted for firearms and heroin offenses), searched Coleman’s residence on April 12, 2011; Coleman and his wife Charisse provided statements implicating Ronald Johnson in heroin distribution.
Coleman told agents he bought 150–200 grams of heroin weekly from Johnson at Unit #310 (the Jackson condominium) and identified Johnson from a driver’s-license photo; he also admitted to possessing guns and heroin in his own residence.
Charisse corroborated long-term association between Coleman and Johnson: they were allegedly Gangster Disciples, had bagged heroin together, and had recently shifted bagging to Johnson’s residence.
Investigators corroborated Johnson’s association with Unit #310 via Accurint (listing him as “associated”), CPD surveillance (following Johnson to/from the condo), and a parking ticket; ATF agents also had records of prior drug convictions for both men.
A magistrate issued a search warrant for Johnson’s condo; agents seized ~4.8 kg of heroin, ~$155,000, scales, baggies, and re-packaging items. Johnson later pleaded guilty while preserving appeal rights as to suppression rulings and sought suppression/Franks relief, which the district court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for search warrant	Affidavit lacked sufficient, reliable informant corroboration; Coleman was an untested, newly arrested, intoxicated informant	Affidavit contained detailed, firsthand admissions by Coleman corroborated by Charisse and independent records tying Johnson to the unit	Probable cause existed based on totality of circumstances; warrant upheld
Need for Franks hearing (alleged omissions/false statements in affidavit)	Affidavit omitted material facts and contained misleading statements that, if corrected, would negate probable cause	Alleged omissions were immaterial or not actually omissions; contradictions arose after warrant	No substantial preliminary showing for Franks hearing; denial affirmed
Good-faith exception alternative	N/A (primary attack on probable cause)	Even if probable cause lacking, agents relied on warrant in objective good faith	Court did not decide on this because it found probable cause; district court’s alternative good-faith ruling not reached by appellate court
Weight of informant statements (statements against penal interest)	Coleman unreliable due to recent heroin use and incentive to lie	Coleman’s admissions were against penal interest, recent, corroborated, and motivated by desire to limit Charisse’s exposure	Court credited statements against penal interest as significant in establishing probable cause

United States v. Glover, 755 F.3d 811 (7th Cir.) (standard of review for suppression rulings)
United States v. Gregory, 795 F.3d 735 (7th Cir.) (totality-of-the-circumstances test for informant-based probable cause)
United States v. Carson, 582 F.3d 827 (7th Cir.) (affidavit-only warrant review)
United States v. Peck, 317 F.3d 754 (7th Cir.) (no single factor dispositive in informant reliability analysis)
United States v. Robinson, 724 F.3d 878 (7th Cir.) (deference to magistrate’s probable-cause determination)
United States v. Olson, 408 F.3d 366 (7th Cir.) (skepticism for newly arrested informants)
United States v. Lake, 500 F.3d 629 (7th Cir.) (statements against penal interest increase informant reliability)
Franks v. Delaware, 438 U.S. 154 (U.S.) (standard for obtaining a Franks hearing)
United States v. Jones, 208 F.3d 603 (7th Cir.) (standard of review for Franks-hearing denials)
United States v. Watts, 535 F.3d 650 (7th Cir.) (discussion of Leon good-faith exception)
United States v. Leon, 468 U.S. 897 (U.S.) (good-faith exception to exclusionary rule)