3:24-cr-00037
S.D. Miss.May 2, 2025Background
- Jabreon Deshon Mosley was investigated for drug trafficking after a confidential citizen source reported he was producing counterfeit pills at his home in Meridian, Mississippi.
- Agents gathered evidence through surveillance, intercepted package shipments, recorded phone calls—with conversations using coded language for drugs—and physical evidence observed at Mosley’s residence.
- In January 2024, agents intercepted a shipment of pill press die molds addressed to Mosley, and subsequently obtained a warrant supported by an 18-page affidavit detailing the investigation.
- Law enforcement executed the search warrant and seized large quantities of drugs, firearms, and drug manufacturing equipment from Mosley’s home.
- Mosley moved to suppress the evidence, claiming the warrant was obtained in bad faith and lacked probable cause.
Issues
| Issue | Mosley’s Argument | Government’s Argument | Held |
|---|---|---|---|
| Good-faith exception to exclusionary rule | Agents acted in bad faith by obtaining warrant with misleading/false statements | Officers reasonably relied on warrant; affidavit provided extensive details | Good-faith exception applies; no reason to suppress evidence |
| Misleading the Magistrate | Affidavit misrepresented number of confidential sources and misstated info origin | Affidavit referenced at least two reliable sources; no evidence of falsity | No false statements, no deliberate misrepresentation |
| Magistrate Abandoning Judicial Role | Magistrate acted merely as a rubber stamp, lacked sufficient info | Magistrate considered a detailed affidavit, acted neutrally | No evidence magistrate abandoned role; argument meritless |
| "Bare bones" Affidavit | Affidavit was conclusory, did not link Mosley to phone calls, no probable cause | Affidavit provided specific facts, linked Mosley to phone number | Affidavit was thorough and detailed; credible basis for warrant |
Key Cases Cited
- Utah v. Strieff, 579 U.S. 232 (describes Fourth Amendment and exclusionary rule)
- United States v. Leon, 468 U.S. 897 (establishes good-faith exception to the exclusionary rule)
- Franks v. Delaware, 438 U.S. 154 (sets standard for evidentiary hearings based on alleged falsehoods in warrant affidavits)
- Davis v. United States, 564 U.S. 229 (clarifies scope of the good-faith exception)
- Riley v. California, 573 U.S. 373 (reinforces need for warrants in most searches)
- Collins v. Virginia, 584 U.S. 586 (defines scope of search under Fourth Amendment)