United States v. Philip Maccani, 49 F.4th 1126

Neighbors called police after Maccani yelled and threatened them over a noisy generator; deputies found him near his trailer with firearms visible and a shotgun tucked in his waistband.
Officers ordered Maccani to show his hands; he went into the trailer, set a firearm down, exited, ignored orders, was wrestled to the ground, handcuffed, and taken to the hospital after injuring his head.
Maccani’s father consented to officers entering the trailer briefly to extinguish a candle; inside an officer observed a sawed-off single-shot 12-gauge shotgun and an air rifle on the bed.
Officers later obtained and executed a search warrant; the search recovered a loaded, shortened 12-gauge shotgun not registered under the National Firearms Act, ammunition, and suspected marijuana.
Maccani was charged with possession of an unregistered NFA firearm, moved to suppress the trailer search and its fruits, the magistrate and district court denied suppression, and Maccani pleaded guilty while reserving the right to appeal the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of search warrant (probable cause and particularity)	Maccani: affiant lacked expertise to ID marijuana; warrant failed to particularly describe items to be seized	Government: affidavit recited officer observations and experience; narrative item descriptions were sufficiently particular	Warrant satisfied Fourth Amendment probable cause and particularity requirements; denial of suppression affirmed
Applicability of Leon good-faith exception	Maccani: reliance unreasonable because affidavit/warrant were deficient and drafted by an officer who executed the search	Government: reliance objectively reasonable; affidavit not deceptive or so lacking in indicia of probable cause as to preclude belief	Even if warrant were deficient, officers reasonably relied on it; good-faith exception applies

United States v. Summage, 481 F.3d 1075 (8th Cir. 2007) (particularity standard is pragmatic; courts apply practical accuracy)
United States v. Gabrio, 295 F.3d 880 (8th Cir. 2002) (probable cause requires a fair probability evidence will be found)
United States v. Ventresca, 380 U.S. 102 (1965) (probable cause may rest on evidence not admissible at trial)
Illinois v. Gates, 462 F.3d 213 (1983) (magistrate’s probable-cause determination reviewed under totality of circumstances; give deference)
Groh v. Ramirez, 540 U.S. 551 (2004) (warrant can be invalid if description of items is wholly deficient)
United States v. Leon, 468 U.S. 897 (1984) (establishes the good-faith exception to the exclusionary rule)
United States v. Proell, 485 F.3d 427 (8th Cir. 2007) (explains Leon exceptions and when reliance is unreasonable)
United States v. $45,000.00 in U.S. Currency, 749 F.3d 709 (8th Cir. 2014) (standard of review for denial of suppression motions)