United States v. Marcus Smith
692 F. App'x 112
| 4th Cir. | 2017Background
- Police obtained six search warrants (with substantially similar affidavits) authorizing GPS tracking of three vehicles registered to Jevae Pope and allegedly operated by Marcus S. Smith; tracking led to search of a stash house where >150 lbs marijuana was seized.
- Affidavits recounted: Smith had been robbed in April 2013; the robber told police Smith was a known drug dealer with over $1 million in product at a stash house; other allegations tied Smith to Pope and the three vehicles.
- Smith moved to suppress the marijuana, arguing the affidavits lacked probable cause and contained misleading or incomplete information about prior marijuana charges, the confidential informant’s tip, and the affiant’s basis for linking Smith to the vehicles.
- The district court denied suppression; Smith appealed that denial to the Fourth Circuit. Smith was later convicted at trial and sentenced to 132 months’ imprisonment (conspiracy and possession with intent to distribute).
- The Fourth Circuit reviewed legal issues de novo and factual findings for clear error and focused on whether officers’ reliance on the warrants was objectively reasonable under the Leon good-faith exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether affidavits lacked probable cause for warrants | Affidavits were misleading/too weak (missing timing, informant basis, criminal-history detail) | Affidavits provided sufficient ties between Smith, Pope, and vehicles; judicial officers found probable cause | Court did not decide probable cause because good-faith exception applies; affirmed denial of suppression |
| Whether good-faith exception to exclusionary rule applies | Leon exception inapplicable because affidavits were misleading or so lacking probable cause reliance was unreasonable | Officers reasonably relied on warrants; multiple superior court judges found probable cause | Good-faith exception applies; reliance on warrants was objectively reasonable |
| Whether omissions/misstatements in affidavits rose to reckless falsity | Omissions and weaknesses show reckless disregard or deliberate misleading | Alleged omissions were weaknesses, not evidence of deliberate or reckless falsehood | Court found no showing of deliberate/reckless falsehood; affidavits not misleading in that sense |
| Whether judicial determinations affect objective reasonableness | N/A | Four NC superior court judges issued warrants, indicating objective reasonableness of reliance | The consensus among judges supports objective reasonableness; reliance was reasonable |
Key Cases Cited
- United States v. White, 850 F.3d 667 (4th Cir.) (standard of review for suppression rulings)
- United States v. Perez, 393 F.3d 457 (4th Cir.) (Leon objective-reasonableness framing)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good-faith exception to exclusionary rule)
- United States v. Doyle, 650 F.3d 460 (4th Cir.) (exceptions to Leon for deliberate falsehoods or reckless disregard)
- United States v. Lalor, 996 F.2d 1578 (4th Cir.) (multiple judicial approvals support objective reasonableness)