Summary
The United States Court of Appeals for the Seventh Circuit affirmed the denial of Ryan Douglas’s motion to suppress evidence obtained from searches of a residence and an iPhone. Although the court viewed the probable-cause basis for both warrants as weak, it held that the officers’ reliance on the warrants was objectively reasonable under the good-faith exception to the exclusionary rule. The court therefore affirmed the district court’s ruling.
Topics
Practice areas
Questions Presented
- Whether the affidavit supporting the warrant to search 1726 N. 16th Street established probable cause to believe evidence of drug crimes would be found there.
- Whether the affidavit supporting the warrant to search Douglas's iPhone established probable cause to believe evidence of drug crimes would be found on that phone.
- Whether the Leon good-faith exception to the exclusionary rule applied to the officers' execution of either warrant even if probable cause was lacking.
Holdings
- Even assuming the residential search warrant lacked probable cause, suppression was unwarranted because Douglas failed to rebut the presumption that officers acted in good faith when they relied on the warrant.
- Even assuming the iPhone warrant lacked probable cause, suppression was unwarranted because the affidavit was not so lacking in indicia of probable cause that the officers' reliance on the warrant was entirely unreasonable.
- The district court properly denied the motion to suppress because the evidence from both searches was admissible under the Leon good-faith exception.
Key quotations
“But this rule has exceptions, including the Leon good-faith exception, which provides that suppression is not warranted when police officers who executed the warrant relied in good faith on the issuing judge’s decision of probable cause.” (6)
“But we do not resolve the issue. The officers who searched 1726 N. 16th Street secured a warrant, so we presume they acted in good faith and thus any evidence they discovered is admissible under Leon’s good-faith exception.” (9)
“While thin, the affidavit here was not “so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable.”” (11)
Factual background
Law enforcement received information from multiple confidential informants that Douglas was selling methamphetamine and cocaine and conducted several controlled buys involving Douglas or a black BMW associated with him. During the final controlled buy, Douglas carried items into 1726 N. 16th Street before completing the drug transaction and then returned to the house, which officers searched under an Illinois warrant. Officers seized cash, including buy money, plastic baggies, digital scales, and inositol powder. They later obtained a warrant to search an iPhone found in Douglas's vehicle during a traffic stop; the search revealed text messages related to drug sales.
Procedural history
A federal grand jury indicted Douglas for distribution of methamphetamine. The district court denied his motion to suppress, adopting a magistrate judge's recommendation that the warrants were supported by probable cause and, alternatively, that the officers acted in good-faith reliance on the warrants. Douglas entered a conditional guilty plea, was sentenced to 84 months' imprisonment, and appealed the suppression ruling.