United States v. Sidney Thompson, 801 F.3d 845

In July 2013 a Peoria County judge issued a state search warrant for Sidney Thompson’s home based solely on Officer Matthew Lane’s affidavit alleging Thompson “routinely sells cocaine” from the residence.
The affidavit reported a confidential informant (CI) had visited Thompson’s house twice in the prior 30 days (most recently within 72 hours) and observed cocaine and Thompson with an off-white rock-like substance represented as cocaine.
Officer Lane corroborated parts of the CI’s report: the CI identified Thompson from a photo array, Thompson’s criminal history and address matched, and surveillance placed Thompson entering and exiting the residence. The affidavit also reported the CI had previously made a controlled marijuana buy and supplied info leading to a prior warrant/arrest.
Police executed the warrant the same day and seized about 17 grams of cocaine; Thompson was federally charged with possession with intent to distribute.
Thompson moved to suppress, arguing the affidavit lacked probable cause (too summary, omitted quantity, basis for CI’s knowledge, and other details) and that Leon’s good-faith exception could not save the search because the affidavit was so facially deficient.
The district court upheld the search—first invoking the good-faith exception from the bench and then issuing a written order finding the affidavit established probable cause; Thompson conditionally pleaded guilty and appealed the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the affidavit established probable cause for the warrant	Affidavit was conclusory and too thin — omitted drug quantity, CI’s basis for knowing substance was cocaine, and other detail	Affidavit contained sufficient indicia (recent observations, ID from photo array, corroboration, CI’s past assistance) to support probable cause	Court expressed skepticism about affidavit’s strength but did not need to resolve probable cause; district court’s finding of probable cause was given deference
Whether evidence is admissible under the good-faith exception (Leon) if probable cause is lacking	Leon exception inapplicable because affidavit was so deficient no officer could reasonably rely on the warrant	Officer Lane’s procurement of a warrant and some corroboration of CI’s info support reasonable reliance; CI’s history of reliable tips and controlled buy further supports good faith	Even if probable cause were lacking, the search is saved by the good-faith exception; evidence admissible

United States v. Leon, 468 U.S. 897 (1984) (establishes good-faith exception to exclusionary rule)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)
United States v. Garcia, 528 F.3d 481 (7th Cir.) (caution about thin informant affidavits)
United States v. Searcy, 664 F.3d 1119 (7th Cir.) (officer’s corroboration supports application of Leon)
Owens v. United States, 387 F.3d 607 (7th Cir.) (value of informant’s estimate of drug quantity to show persistence of evidence)
United States v. Sutton, 742 F.3d 770 (7th Cir.) (factors for evaluating informant-based probable cause)