United States v. Leonard, 17 F.4th 218

Lewiston police obtained a state search warrant for Apartments #2 and #3 at 41 Walnut St. after an affidavit by Patrolman Provost relying on information from three known confidential informants and a controlled buy.
The affidavit identified "TOMCAT" as Tony Leonard, described use of a second-floor "trap" apartment for dealing, a third-floor apartment where Leonard lived, video surveillance of common areas, and prior observations of drugs and firearms.
During execution officers found Leonard in Apt. #3, a jacket with a handgun, cocaine/crack, over $10,000, a key to Apt. #2, and drug-related items in Apt. #2 tied to Leonard.
Leonard moved for a Franks hearing, alleging two material omissions from the affidavit: (1) the electronic recording placed on the CI produced unusable audio due to background noise; and (2) after the controlled buy the CI rode away with an unidentified person before meeting officers, raising doubt who supplied the drugs.
The district court denied the Franks motion and suppression request, accepting Leonard's factual allegations but finding the omitted facts would not vitiate probable cause; Leonard pleaded guilty conditionally and appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Leonard made the substantial preliminary showing required for a Franks hearing that intentional/reckless omissions in the warrant affidavit vitiated probable cause	Leonard: Omitted facts (unusable recording; CI left with unknown person) were material and would have undermined the controlled-buy corroboration, so Franks hearing required	Government: The omissions were not material; the affidavit still supplied probable cause based on multiple corroborating CIs and investigatory corroboration; alternatively officers acted in good faith on the warrant	Court: Denied Franks hearing. Even with the omitted facts added, the totality of corroboration from three CIs, independent checks, and the buy sufficed to establish probable cause.
Whether the affidavit (as reformed) established a nexus to the third-floor apartment specifically	Leonard: The reformed affidavit would show only drug activity on second floor; no sufficient nexus to search Leonard's third-floor residence	Government: The affidavit combined common-sense inferences about where dealers store drugs/records/cash with specific facts linking activities to the building and to Leonard, supporting nexus to both apartments	Court: Held nexus established. Reformed affidavit still provided a fair probability that evidence would be found in the third-floor apartment.

Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (framework for challenging warrant affidavits for false statements or omissions)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (U.S. 1983) (totality-of-circumstances probable-cause standard)
United States v. Tiem Trinh, 665 F.3d 1 (1st Cir. 2011) (factors for assessing CI-based probable cause)
United States v. Barnard, 299 F.3d 90 (1st Cir. 2002) (value of cross-corroboration and CI reliability evidence)
United States v. Khounsavanh, 113 F.3d 279 (1st Cir. 1997) (controlled buys can corroborate CI reports despite imperfections)
United States v. Feliz, 182 F.3d 82 (1st Cir. 1999) (nexus analysis for residence searches)
United States v. Roman, 942 F.3d 43 (1st Cir. 2019) (inferring nexus from type of crime and specific supporting facts)