Summary
The United States Court of Appeals for the Sixth Circuit affirmed the denial of Devin Long’s motion to suppress evidence seized from his residence under a search warrant. The court held that the warrant affidavit established probable cause and a sufficient nexus between Long’s home and ongoing drug-trafficking activity, including observations of suspected transactions and surveillance connecting Long to drug stash locations. Judge Bloomekatz concurred in the judgment, emphasizing that probable cause should be assessed under the totality of the circumstances rather than through segmented analyses.
Topics
Practice areas
Questions Presented
- Whether the affidavit supporting the search warrant established probable cause and a sufficient nexus between Long's residence and evidence of drug trafficking.
- Whether the district court properly denied Long's motion to suppress evidence seized from his residence.
Holdings
- The affidavit established probable cause because it showed that the residence was Long's home and that Long was engaged in ongoing and continuous drug trafficking, creating a sufficient nexus between the residence and evidence of criminal activity.
- The absence of facts such as the quantity of drugs sold, additional drug-related criminal history, international trafficking evidence, or eyewitness information from inside the residence did not defeat probable cause.
Key quotations
“The probable cause determination takes place on the front lines” (4)
“The affidavit established that Long was a known drug dealer engaged in ongoing trafficking operations who lived at the home to be searched, a location where, experience and common sense teaches, evidence was likely to be found. That is quintessential probable cause.” (4)
“So when officers have evidence of even one drug deal immediately outside of the home of a dealer, there is probable cause to search the home.” (8)
“All that is necessary is a “‘fair probability’ or a ‘common-sense’ inference” that evidence of criminal activity will be found.” (9)
Factual background
Law-enforcement officers surveilled Devin Long and his associates during an investigation of methamphetamine, fentanyl, and cocaine trafficking. Officers observed Long participate in conduct connected to controlled buys, travel repeatedly between a suspected drug stash house and his registered residence, and engage in what appeared to be a drug transaction outside his home. A warrant search of Long's residence uncovered multiple controlled substances, six firearms, ammunition, magazines, cutting agents, and other evidence of drug trafficking.
Procedural history
Federal officers obtained a warrant to search Long's residence for evidence of drug trafficking after surveillance of Long and his associates, including controlled buys and suspected drug transactions. The search yielded drugs, firearms, ammunition, and related items. The district court denied Long's suppression motion, after which he pleaded guilty to four charges and was sentenced to 15 years. The Sixth Circuit affirmed.