United States v. Zachary Reed, 921 F.3d 751

Deputies executed an arrest warrant for Reed at his home after tips that he manufactured meth; officers observed Heet bottles, Coleman fuel, and tubing on the property.
Deputy Boatman visited evening and later at night, approached the back deck/back door and saw a glass beaker; he left without entry. He was uncertain which door was primary.
Deputy Vanderfeltz later went to execute the arrest warrant, walked to the back deck, saw the beaker, and contacted Narcotics Officer Parish.
Parish field-tested the beaker (positive for meth), then obtained a search warrant recounting tips from other officers and an anonymous citizen plus the beaker and other items; the warrant issued and police seized meth-production materials.
Reed pled guilty to possessing equipment reasonably believed to be used to manufacture a controlled substance but reserved the right to appeal the denial of his suppression/Franks motions.

Issue	Reed's Argument	Government's Argument	Held
Lawful presence on back deck / plain-view beaker	Boatman’s night visit was unlawful; beaker observed during that visit must be excluded	Even if Boatman’s second visit was unlawful, Vanderfeltz independently would have seen the beaker while lawfully executing the warrant	Beaker admissible: no but-for causation from any alleged illegal visit; Vanderfeltz lawfully on deck given totality of circumstances
Franks challenge: omissions/reckless disregard	Parish omitted that source info was merely hearsay and omitted other benign auto-repair items, recklessly disregarding truth so affidavit lacked probable cause	Affidavit properly relied on other officers/anonymous tip corroborated by observable items; omissions not shown to be reckless or clearly critical	No Franks violation: Reed failed to show reckless omission that would negate probable cause
Veracity of statement that beaker was in plain view	Boatman’s possible illegal entry makes the statement false/tainted	Vanderfeltz and Parish lawfully observed the beaker; no indication Parish knew of an illegal entry	Statement stands: officers lawfully on deck and no evidence Parish knew of any illegality
Probable cause for search warrant	Without the beaker (or with omitted facts), affidavit lacks probable cause	Information from officers and anonymous citizen was corroborated by Heet cans, fuel, and beaker, supplying probable cause	Probable cause existed under the totality of circumstances; warrant valid

United States v. Leon, 468 U.S. 897 (1984) (exclusionary-rule limits for evidence used to obtain warrants)
Segura v. United States, 468 U.S. 796 (1984) (suppression not required unless evidence is product of illegal activity)
Illinois v. Gates, 462 U.S. 213 (1983) (totality-of-the-circumstances test for probable cause)
Franks v. Delaware, 438 U.S. 154 (1978) (standards for challenging affidavits for omissions or false statements)
Hudson v. Michigan, 547 U.S. 586 (2006) (limits on suppression remedy where constitutional violation did not cause obtaining evidence)
Oliver v. United States, 466 U.S. 170 (1984) (Fourth Amendment protection of curtilage)
Payton v. New York, 445 U.S. 573 (1980) (officer authority to enter dwelling to execute arrest warrant when reasonable belief suspect present)
United States v. Raines, 243 F.3d 419 (8th Cir. 2001) (plain-view exception elements)
United States v. Buchanan, 574 F.3d 554 (8th Cir. 2009) (informant reliability established by corroboration)
United States v. Conant, 799 F.3d 1195 (8th Cir. 2015) (Franks reckless-disregard standard)