United States v. Rodney Hamilton Higgins, Jr.
141 F.4th 811
| 6th Cir. | 2025Background
- Rodney Higgins was investigated for participation in a methamphetamine and fentanyl distribution ring from June to August 2021.
- Law enforcement used a confidential source to conduct two controlled drug purchases from Higgins.
- Based on evidence including Higgins’s texts and prior drug dealings, a magistrate issued a warrant to search his apartment.
- The search uncovered significant amounts of methamphetamine and fentanyl.
- Higgins moved to suppress the evidence, arguing inadequacies in the search warrant; the district court denied the motion. Higgins pleaded guilty but preserved his right to appeal the suppression denial.
Issues
| Issue | Higgins's Argument | Government's Argument | Held |
|---|---|---|---|
| Nexus between drug trafficking and residence | Insufficient link between drug activity and his apartment | Higgins was a known drug dealer and directed sales from his residence | Sufficient nexus; probable cause found |
| Staleness of information for probable cause | Info from controlled buys was outdated (55 days old) | Recent texts indicating imminent drug sale refreshed any staleness | Recent communications refreshed probable cause |
| Sufficiency of evidence in affidavit | Texts and calls did not prove drugs were present in the apartment | Probable cause only requires a 'fair probability,' not absolute certainty | Probable cause standard met |
| Entitlement to a Franks hearing (affidavit issues) | Affidavit contained misrepresentations or omitted key facts | No knowing/reckless falsity or intentional/critical omissions shown | No Franks hearing required |
Key Cases Cited
- District of Columbia v. Wesby, 583 U.S. 48 (probable cause is a low threshold requiring only a fair probability)
- United States v. Sanders, 106 F.4th 455 (probable cause to search a known drug dealer’s residence established by ongoing operations)
- United States v. Simmons, 129 F.4th 382 (extensive/repeated drug dealings and past convictions show dealer status)
- Franks v. Delaware, 438 U.S. 154 (outlines requirements for a hearing on affidavit truthfulness)
- United States v. Frechette, 583 F.3d 374 (staleness doctrine in probable cause)
- United States v. Spikes, 158 F.3d 913 (fresh activity can revive stale information in warrants)
- United States v. Bateman, 945 F.3d 997 (review standard for district court determination on Franks claims)