United States v. Ronald Coleman, Jr., 923 F.3d 450

Law enforcement investigated Eddie Powell and identified Ronald Coleman as a source via a cooperating informant who completed multiple controlled buys.
Officers observed Coleman drive to Powell’s home in both a Buick Enclave and a Trailblazer; one observed stop at Powell’s lasted only minutes and another sale occurred days later.
Coleman’s vehicles were registered to his father; Coleman had prior felony drug convictions—facts included in affidavits for tracking warrants.
On April 19, 2017, magistrate judge issued warrants to install GPS trackers on both vehicles; ATF agents installed trackers by parking on a public spot and approaching the cars at Coleman’s condominium complex.
GPS data and observed controlled buys supported a May 23, 2017 warrant to search Coleman’s condominium; execution recovered ~500g cocaine, a firearm, and financial records. Coleman pleaded guilty but preserved suppression appeal; district court denied suppression and the Sixth Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for vehicle-tracking warrant	Warrant lacked sufficient nexus/evidence linking Enclave to drug distribution	Affidavit included informant ID, observed stops, prior convictions, registration to father—sufficient to believe tracking would yield evidence	Probable cause existed; warrant upheld
Entry onto condominium complex	Agent unlawfully entered private property (sign present)	Sign did not bar entry; complex was open and accessible to public/visitors	No Fourth Amendment violation in entering complex
Intrusion onto curtilage by walking on driveway to attach tracker	Walking onto driveway was a search of curtilage under Collins and thus unconstitutional without warrant	Driveway was unenclosed, shared, visible to passersby, and functioned as common access—not curtilage	Not curtilage; no Fourth Amendment violation when agent attached tracker
Probable cause for residential search warrant	Warrant lacked nexus tying drugs to home	Affidavit showed multiple controlled buys, observation of Coleman leaving home and traveling directly to buy; vehicles regularly parked at residence	Magistrate could reasonably infer drugs/evidence would be at residence; warrant upheld

Collins v. Virginia, 138 S. Ct. 1663 (2018) (driveway area enclosed and adjacent to house constitutes curtilage)
United States v. Dunn, 480 U.S. 294 (1987) (four-factor test for curtilage analysis)
United States v. Faulkner, 826 F.3d 1139 (8th Cir. 2016) (upholding tracking warrant on weaker facts)
United States v. McNeal, 818 F.3d 141 (4th Cir. 2016) (upholding tracking warrant where vehicle registered to suspect’s mother and corroborative activity present)
United States v. Galaviz, 645 F.3d 347 (6th Cir. 2011) (driveway adjacent to home not curtilage where unenclosed and visible)
United States v. Jones, 893 F.3d 66 (2d Cir. 2018) (shared driveway of multi-family building not within private home curtilage)
United States v. Brown, 828 F.3d 375 (6th Cir. 2016) (warrant nexus requires surveillance or direct link to residence)
United States v. Williams, 544 F.3d 683 (6th Cir. 2008) (magistrate may infer dealers store drugs at home)
United States v. Helton, 314 F.3d 812 (6th Cir. 2003) (insufficient nexus where affidavit relied on anonymous tip)
United States v. Higgins, 557 F.3d 381 (6th Cir. 2009) (reliability and corroboration required for tip-based probable cause)