United States v. Johntez Randle, 39 F.4th 533

Minneapolis officer Efrem Hamilton used a confidential reliable informant (CRI) to conduct a controlled buy of suspected crack cocaine from Johntez Randle within 72 hours before applying for a search warrant.
Hamilton’s warrant affidavit identified Randle, described the controlled buy, stated the CRI positively identified Randle, and said officers followed Randle to a Vera Cruz Lane residence listed as his supervised-release address.
A warrant was issued and executed the same day; police seized 308 grams of crack cocaine and related evidence from the residence and from bags Randle carried.
Randle moved to suppress the seized evidence, arguing the affidavit lacked a sufficient nexus showing to the Vera Cruz residence and therefore lacked probable cause.
The district court concluded the affidavit may have been deficient on the nexus point but denied suppression under the Leon good‑faith exception and denied Randle’s request for a Franks hearing challenging alleged omissions in the affidavit.
Randle appealed the denial of suppression and the denial of a Franks hearing; the Eighth Circuit affirmed both rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the search warrant affidavit established probable cause/nexus to search the Vera Cruz residence	Affidavit omitted direct nexus facts; did not show officers followed Randle directly after buy or that contraband likely at that residence	Affidavit included controlled buy, CRI ID, and officers following Randle to the listed supervised‑release address — and reliance on the warrant was objectively reasonable	Court assumed possible nexus deficiency but held Leon good‑faith exception applied; officer’s reliance on the warrant was reasonable, so evidence admissible
Whether Randle made the substantial preliminary showing required for a Franks hearing based on omission of a Stevens Avenue address in state records	Omitting state records showing a different Stevens Ave address was a material omission that, if disclosed, would undercut the affidavit’s assertion that Vera Cruz was Randle’s home and negate probable cause	Hamilton knew of other addresses but reasonably relied on Probation Office records listing Vera Cruz as Randle’s current supervised‑release address; omission not shown to be intentional or recklessly misleading	Court held Randle failed to make the required substantial preliminary showing; denial of Franks hearing and discovery was not an abuse of discretion

United States v. Leon, 468 U.S. 897 (U.S. 1984) (establishes good‑faith exception to the exclusionary rule)
Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (requires evidentiary hearing if defendant makes substantial preliminary showing of intentional or reckless falsehood/omission in affidavit)
United States v. Grant, 490 F.3d 627 (8th Cir. 2007) (applies Leon objective good‑faith standard)
United States v. Carpenter, 341 F.3d 666 (8th Cir. 2003) (Leon applies despite multiple affidavit infirmities when officer’s reliance is reasonable)
United States v. Herron, 215 F.3d 812 (8th Cir. 2000) (distinguishes affidavits that focus suspicion on a separate suspect)
United States v. Tellez, 217 F.3d 547 (8th Cir. 2000) (requires nexus between place searched and contraband)
United States v. Ross, 487 F.3d 1120 (8th Cir. 2007) (officer’s professional judgment about where dealers store contraband can support nexus inference)
United States v. Short, 2 F.4th 1076 (8th Cir. 2021) (government need only show facts sufficient to support probable cause in affidavit)
United States v. Kattaria, 553 F.3d 1171 (8th Cir. 2009) (quoting Franks standard)
United States v. Carnahan, 684 F.3d 732 (8th Cir. 2012) (omitted material must be clearly critical to infer reckless disregard)
United States v. Arnold, 725 F.3d 896 (8th Cir. 2013) (substantial preliminary showing requirement is not lightly met)