United States v. Robert Cortez Burrell, 114 F.4th 537

DEA agents received an anonymous tip in September 2020 that Robert Cortez Burrell was trafficking drugs from multiple Michigan residences.
Four months of surveillance, GPS tracking, and corroboration (including purchases by a third party and utility records) connected Burrell to drug dealing.
Search warrants executed at four locations recovered large quantities of narcotics, firearms, cash, and drug-manufacturing tools.
Burrell was charged with federal drug, firearm, and ammunition offenses and convicted on all counts after a jury trial.
He moved to suppress the evidence, challenged the constitutionality of his felon-in-possession charges under the Second Amendment, and raised Confrontation Clause and evidentiary objections at trial; each motion was denied by the district court.

Issue	Burrell's Argument	Government's Argument	Held
Suppression of Search Evidence	Warrants lacked probable cause; insufficient corroboration of anonymous tip; no nexus to residences.	Agents corroborated tip with surveillance/GPS/records, establishing probable cause and nexus.	Denied; affidavits sufficiently supported probable cause and nexus; good-faith exception applied.
Constitutionality of § 922(g)(1) Charges	Facial/as-applied Bruen challenge; late motion excused by new law; ineffective counsel.	Motion untimely and meritless; courts uphold § 922(g)(1); no clear ineffective assistance.	Motion untimely; no plain error; § 922(g)(1) challenges fail under plain-error review.
Admission of Hearsay and Confrontation Clause	Agent's recounting of informant's statements violated both rules.	Testimony explained investigative actions, not offered for truth; not hearsay.	No violation; out-of-court statements not offered for truth, so not hearsay or unconstitutional.
Agent Credibility Testimony and Prosecutorial Misconduct	Agent improperly opined on gas-station clerk's credibility; misconduct by prosecution.	Testimony was helpful context, not vouching; prosecution did not comment or bolster.	No plain error; agent's opinion admissible, no prosecutorial misconduct or evidentiary breach.

Illinois v. Gates, 462 U.S. 213 (1983) (set out "totality of the circumstances" test for probable cause in warrant applications).
United States v. Leon, 468 U.S. 897 (1984) (set forth the good-faith exception to the exclusionary rule for evidence seized under a defective warrant).
United States v. Carpenter, 360 F.3d 591 (6th Cir. 2004) (en banc) (requirement of a specific and concrete nexus between the place searched and evidence sought).
United States v. Crawford, 943 F.3d 297 (6th Cir. 2019) (review of probable cause for warrants is limited to the four corners of the affidavit).
Minnesota v. Carter, 525 U.S. 83 (1998) (Fourth Amendment standing requires expectation of privacy in the searched premises).
United States v. Cromer, 389 F.3d 662 (6th Cir. 2004) (statements not admitted for truth are not hearsay and not barred by Confrontation Clause).