Case Explained: UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT UNITED STATES OF AMERICA v. WILLIE DAVID LARK ) ) ) ) ) ) ) ) ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MICHIGAN O P I N I O N

Court: United States Court of Appeals for the Sixth Circuit

Filed: 2026-07-08

The Sixth Circuit affirmed the conviction of Willie David Lark for drug trafficking, rejecting his challenges to the denial of a motion to suppress evidence, the refusal to hold a *Franks* hearing, and the Speedy Trial Act dismissal motion. The court held that the search warrants were supported by probable cause under the Fourth Amendment, applying the “totality of the circumstances” test to determine if there was a fair probability that contraband would be found in the vehicle or residence. The panel found sufficient evidence based on multiple credible confidential informants with established track records, controlled buys, and tracking data linking Lark’s red pickup truck and South Fair Avenue residence to drug activity. Regarding the *Franks* hearing request, the court applied the standard requiring a substantial preliminary showing of knowing, intentional, or reckless falsehoods in the warrant affidavits; it concluded that variations in affidavit details were not contradictory and that Lark failed to prove any omissions were made with intent to mislead or were critical to probable cause. On the Speedy Trial Act claim, the court determined that the district court properly exercised its discretion under 18 U.S.C. § 3161(h)(7)(A) to grant an “ends of justice” continuance while awaiting an en banc decision in *United States v. Sanders*, noting that the reasons for the delay were clear from the record and provided before the ruling on the dismissal motion. As a result, Lark’s conviction and 360-month sentence remain in effect.

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