United States v. Tyrone Lyles
910 F.3d 787
4th Cir.2018Background
- Prince George’s County police, investigating an unrelated homicide, found four green trash bags at the curb near 9010 Ridgewood Dr.; inside: three marijuana stems (tested positive), three empty rolling-paper packs, and mail addressed to the residence.
- Police affidavit omitted the unrelated homicide investigation details and did not name Lyles; it asserted from training/experience that marijuana and handguns were likely at the address.
- A state magistrate issued a broad search warrant authorizing an in‑home, whole‑house search and seizure of numerous categories of items (including cell phones, computers, records, jewelry, and firearms).
- Officers executed the warrant and seized four handguns, ammunition, marijuana, and paraphernalia; Lyles was indicted under 18 U.S.C. § 922(g) as a felon in possession.
- The district court suppressed the evidence, holding the trash pull did not establish a fair probability of additional marijuana in the home and the warrant was plainly overbroad; the government appealed.
Issues
| Issue | Plaintiff's Argument (Government) | Defendant's Argument (Lyles) | Held |
|---|---|---|---|
| Whether the trash pull supplied probable cause to search the home for marijuana possession | Three marijuana stems, rolling papers, and mail tied to the address support a fair probability additional marijuana would be found inside | Tiny quantity in a single trash pull, without corroboration, is insufficient to show a fair probability of contraband in the home | No: magistrate lacked a substantial basis for probable cause to search for marijuana |
| Whether the warrant was sufficiently particular and not overbroad | Warrant authorized by magistrate; broad categories reasonably related to drug possession investigation | Warrant resembled a general warrant, authorizing seizure of items (phones, computers, jewelry, personal effects) not plausibly connected to small‑scale marijuana possession | Warrant was plainly overbroad and not justified by the sparse trash evidence |
| Whether the good‑faith exception (Leon) saves the search despite defects | Officers reasonably relied on a warrant reviewed by supervisor and prosecutor; undisclosed officer tip about Lyles being a dealer supports objective reasonableness | The affidavit’s defects were obvious; undisclosed, vague tips do not cure lack of probable cause; magistrate review is required | No: good‑faith exception does not apply because reliance was not objectively reasonable given the thin affidavit and obvious overbreadth |
Key Cases Cited
- California v. Greenwood, 486 U.S. 35 (1988) (curbside trash searches without warrant do not violate the Fourth Amendment)
- Illinois v. Gates, 462 U.S. 213 (1983) (probable cause is a practical, common‑sense assessment of fair probability)
- United States v. Leon, 468 U.S. 897 (1984) (good‑faith exception to exclusionary rule when officers reasonably rely on a warrant)
- Riley v. California, 134 S. Ct. 2473 (2014) (cell phones implicate substantial privacy interests distinct from other personal effects)
- Arizona v. Gant, 556 U.S. 332 (2009) (limits on vehicle searches incident to arrest and caution about overbroad searches following minor infractions)
- Florida v. Jardines, 569 U.S. 1 (2013) (home occupies a special place under the Fourth Amendment)
- Welsh v. Wisconsin, 466 U.S. 740 (1984) (seriousness of underlying offense relevant to reasonableness of home entry)
- Kentucky v. King, 563 U.S. 452 (2011) (reasonableness is central to Fourth Amendment searches and seizures)
- United States v. Montieth, 662 F.3d 660 (4th Cir. 2011) (upholding a warrant where trash pull produced extensive indicia of trafficking)
- United States v. Gary, 528 F.3d 324 (4th Cir. 2008) (trash pull corroborated an anonymous tip when it produced trafficking‑related packaging and residue)