United States v. Evans – Do It For The Caselaw

Holding: The court affirmed the district court's denial of the motion to suppress, holding that the good-faith exception applied because the warrant application was not so lacking in probable cause as to render reliance unreasonable.
Standard: good-faith exception
Vote: Unanimous per curiam affirmation.
Practical effect: The decision reinforces the application of the good-faith exception in the Fourth Circuit when a warrant application contains sufficient probable cause, even if the defendant alleges omissions in the affidavit.

The Fourth Circuit affirmed a district court ruling denying a motion to suppress evidence seized from a defendant's home. The court held that the search warrant application contained sufficient indicia of probable cause to trigger the good-faith exception to the exclusionary rule.

Background

Rodney Lamont Evans pleaded guilty to possession with intent to distribute drugs and possession of a firearm in furtherance of a drug trafficking crime. He challenged a district court ruling that denied his motion to suppress evidence seized at his home following the issuance of a search warrant by a Hertford County magistrate judge. The evidence included approximately one thousand seven hundred fifty grams of marijuana, three hundred sixty-five grams of powder cocaine, seven grams of crack cocaine, and a forty-five caliber pistol.

The court’s reasoning

The court reviewed the district court’s application of the good-faith exception to the exclusionary rule. It determined that the affidavit and oral statements to the magistrate judge were not so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable. The court agreed with the trial judge that the affidavit and contemporaneous statements rendered reliance on the issuing warrant objectively reasonable.

the affidavit and contemporaneous statements rendered reliance on the issuing warrant objectively reasonable

Suppression Ruling 13

What it means going forward

The decision reinforces the application of the good-faith exception in the Fourth Circuit when a warrant application contains sufficient probable cause, even if the defendant alleges omissions in the affidavit.