United States v. White
3:23-cr-30022
D. Mass.May 16, 2025Background
- In June 2023, law enforcement searched Lamiek White’s residence (a third-floor apartment in Springfield, MA) under a warrant supported by an FBI investigation into heroin/fentanyl distribution.
- The investigation included a series of controlled drug purchases by a cooperating witness (CW-1), physical surveillance, wiretaps, GPS tracking, and pole cameras over approximately 10 months.
- Seven detailed controlled purchases by CW-1 took place from November 2022 through April 2023, with surveillance showing White frequently accessing his residence in connection with these transactions.
- Additional surveillance and intercepted communications in April, May, and June 2023 indicated ongoing involvement in narcotics activity, including negotiations for large quantities of fentanyl/heroin.
- White moved to suppress all evidence from the search, arguing the affidavit lacked probable cause due to reliance on stale and unreliable informant information and a weak nexus to his residence.
Issues
| Issue | White's Argument | Government's Argument | Held |
|---|---|---|---|
| Probable Cause via CW-1 | CW-1’s info unreliable, too dependent on hearsay | CW-1 had a history of reliability, info corroborated by surveillance | Affidavit established reliability through corroboration and procedure |
| Staleness of Information | Info was too old; no recent controlled buys | Buying pattern ongoing; recent communications/significant purchases | Pattern and recent activity supported probable cause |
| Nexus to Residence | No sufficient link between drugs and White’s home | Surveillance repeatedly showed nexus to residence | Affidavit demonstrated likely ongoing use of home for trafficking |
| Good Faith Exception | Not directly challenged by White | Officers relied in good faith on magistrate's warrant | Good faith exception would apply even if probable cause lacking |
Key Cases Cited
- United States v. Leon, 468 U.S. 897 (1984) (establishing the good faith exception to the exclusionary rule for evidence obtained in reliance on a defective warrant)
- United States v. Sylvestre, 78 F.4th 28 (1st Cir. 2023) (defining probable cause and totality-of-circumstances analysis for search warrants)
- United States v. Tiem Trinh, 665 F.3d 1 (1st Cir. 2011) (detailing factors for sufficiency of information provided by informants in affidavits)
- United States v. Gonzalez Arias, 946 F.3d 17 (1st Cir. 2019) (staleness doctrine in relation to ongoing criminal activity and search warrants)