United States v. Moore, 2011 U.S. App. LEXIS 23344

Moore was convicted in the Western District of Tennessee after pleading guilty to two counts of being a felon in possession of a firearm under 18 U.S.C. § 922(g).
Moore challenged the district court’s denial of his motion to suppress evidence seized under a search warrant for a Memphis apartment, arguing the warrant was invalid and the good-faith exception should not apply.
The warrant was based on a confidential informant (CI) tip alleging trafficking from the described residence; the warrant described the apartment, items to be searched for, and identified the described subject as 'Lil Toe' with generic physical descriptors.
Det. Sathongnhoth executed the warrant on October 25, 2008; firearms, drugs, a scale, and cash were found; Moore arrived soon after and later admitted ownership of drugs and one firearm after waiving rights and being questioned.
The district court denied Moore’s suppression motion, noting the magistrate found probable cause and indicating the word 'storing' was corroborated by plain-view drugs found at the residence.
On appeal, the Sixth Circuit ultimately upheld the warrant, applying the good-faith exception if necessary, and affirmed Moore’s conviction and sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there probable cause for the warrant?	Moore argues the affidavit was minimal and ideational; lacks specificity and reliability about CI, weakening probable cause.	Moore asserts the warrant fails to demonstrate probable cause due to boilerplate language and no solid corroboration.	Probable cause established under Gates totality-of-the-circumstances standard.
Does the good-faith exception apply given the warrant's deficiencies?	If the warrant is defective, suppression should follow unless good faith clearly applies to all four Leon exceptions not met here.	Even if warrant imperfect, officers reasonably relied on magistrate’s decision; good-faith exception should apply.	Good-faith exception applies; suppression not required.
Did the 'storing' statement render the warrant invalid?	Word 'storing' was not supported by the informant’s statements about drug storage at the residence.	Even if 'storing' is challenged, the remaining information supports probable cause and nexus.	Warrant information sufficient to support probable cause even if 'storing' had arguable validity issues.

Illinois v. Gates, 462 U.S. 213 (1983) (probable cause analyzed under totality of the circumstances)
United States v. Jenkins, 396 F.3d 751 (6th Cir. 2005) (totality-of-the-circumstances approach to probable cause)
United States v. Williams, 224 F.3d 530 (6th Cir. 2000) (CI reliability and corroboration considerations supporting probable cause)
United States v. Allen, 211 F.3d 970 (6th Cir. 2000) (en banc; reliability and personal knowledge affect probable cause)
United States v. Finch, 998 F.2d 349 (6th Cir. 1993) (form affidavits and corroboration considerations in probable cause)
United States v. McPhearson, 469 F.3d 518 (6th Cir. 2006) (nexus and probable cause in residence searches)
United States v. Spikes, 158 F.3d 913 (6th Cir. 1998) (factors for staleness and adequacy of warrant particulars)
United States v. Rodriguez-Suazo, 346 F.3d 637 (6th Cir. 2003) (informant reliability and corroboration considerations)
United States v. Weaver, 99 F.3d 1372 (6th Cir. 1996) (information under oath and reliability of underlying facts)
United States v. Hammond, 351 F.3d 765 (6th Cir. 2003) (informant reliability and corroboration in probable cause)