United States v. Lamon David Simmons, 129 F.4th 382

Lamon Simmons was investigated for drug trafficking, with the Grand Rapids Vice Unit using a reliable confidential informant for multiple controlled cocaine buys.
Surveillance showed Simmons primarily resided at a Weatherwood Drive home, which he listed as his address while on federal probation; he also used a separate stash house for dealing (Holly Street).
Based on investigation and the informant’s information, police obtained search warrants for both homes.
The Weatherwood warrant was supported by an affidavit relying on observed behavior, the informant’s buys, and the officer’s experience that profit-type drug traffickers keep records in their residences.
The searches led to substantial evidence (drugs, cash, weapons) and Simmons was charged federally; he moved to suppress the Weatherwood evidence, arguing the warrant lacked probable cause because it didn’t show a nexus to drug activity.
The district court denied the motion, Simmons entered a conditional guilty plea, and timely appealed the suppression denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there probable cause (nexus) for the warrant to search Simmons’s residence?	No sufficient nexus; warrant didn’t show link between home and evidence of drug crimes.	The investigation showed Simmons as a profit-type trafficker with ongoing activity, making it likely evidence/records would be at his home.	Court affirmed a sufficient nexus and probable cause was present.
Was use of a confidential informant proper for establishing probable cause?	Informant's info not enough to tie home to alleged crimes; reliability questioned.	Informant was reliable, well-tested, and engaged in multiple buys observed and confirmed by police.	Court found the informant’s information reliable and credible.
Do recent Sixth Circuit precedents require more concrete/specific evidence of nexus?	Recent caselaw (post-Sanders) sets stricter standards; status as drug dealer alone not enough.	Ongoing activity, proven residence, and credible informant are enough under circuit precedent.	Court rejected the plaintiff’s reading; totality of evidence sufficient.
Should exclusion be avoided under the good faith exception if probable cause was lacking?	Warrant was so lacking it was ‘bare bones,’ so no good faith reliance possible.	Officers reasonably relied on the affidavit and judge’s approval; not ‘bare bones.’	Concurrence: Good faith exception would have applied regardless.

Illinois v. Gates, 462 U.S. 213 (totality-of-circumstances governs probable cause for warrants)
United States v. Carpenter, 360 F.3d 591 (en banc) (warrant requires substantial basis linking evidence and place)
United States v. Gunter, 551 F.3d 472 (repeated/ongoing drug transactions support inference of home nexus)
United States v. Jones, 159 F.3d 969 (circumstantial evidence may establish probable cause to search residence of drug dealer)
United States v. Reed, 993 F.3d 441 (6th Cir.) (probable cause to search dealer's residence given continual and ongoing operations theory)
United States v. Dyer, 580 F.3d 386 (reliability of known informant who witnesses criminal activity firsthand)