United States v. Olivas-Hinojos, 637 F. App'x 140

Efren Olivas-Hinojos pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine but reserved the right to appeal only the validity of the search warrant.
He was sentenced to 180 months imprisonment and five years supervised release.
The district court denied his motion to suppress evidence obtained from a search; the denial rested on consent and the good-faith exception to the exclusionary rule (alternative grounds).
On appeal Olivas-Hinojos challenged: (1) sufficiency of the affidavit supporting the warrant, (2) inapplicability of the good-faith exception, (3) that his consent did not extend to vehicles on the property, and (4) that his detention lacked probable cause.
The Fifth Circuit reviews suppression denials for factual findings under clear-error and legal conclusions de novo, and permits conditional guilty pleas to preserve specified issues on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of search warrant affidavit	Affidavit insufficient to support issuance of warrant	Magistrate had probable cause; warrant valid	Not addressed on merits because district court relied on alternative grounds and appellant failed to preserve/brief challenges
Applicability of good-faith exception	Good-faith exception should not apply	Good-faith exception applies to bar suppression	Abandoned on appeal for lack of briefing; court affirmed on alternative grounds
Scope of consent (vehicles on property)	Consent did not extend to vehicles located on the property	Consent exception justified the search of property and vehicles	Outside scope of preserved appeal; issue not considered
Lawfulness of detention / probable cause	Detention was unlawful and lacked probable cause	Detention supported probable cause / lawful	Outside scope of preserved appeal and abandoned for lack of briefing

United States v. Pack, 612 F.3d 341 (5th Cir. 2010) (standard of review for suppression rulings)
United States v. Bell, 966 F.2d 914 (5th Cir. 1992) (conditional guilty pleas preserve specified issues on appeal)
United States v. Wise, 179 F.3d 184 (5th Cir. 1999) (conditional pleas must explicitly designate issues preserved)
United States v. Scroggins, 599 F.3d 433 (5th Cir. 2010) (issues not briefed are abandoned)
United States v. Cherno, 184 F.3d 403 (5th Cir. 1999) (two-step inquiry for warrant-based suppression: good-faith exception then probable cause review)
United States v. Mays, 466 F.3d 335 (5th Cir. 2006) (affirmance on good-faith grounds absent novel legal question)
United States v. Jackson, 596 F.3d 236 (5th Cir. 2010) (declining to address affidavit sufficiency when district court denied suppression on alternative grounds)