In March 2024, law enforcement officers in Starkville, Mississippi, executed a search warrant at the home of Lexus Sanchez Weaver based on an affidavit drafted by Officer Garrett Mittan. The affidavit relied on a confidential informant who participated in three controlled drug buys of crack cocaine from Weaver, all conducted under continuous police surveillance. The warrant was approved by a municipal judge via FaceTime during the pandemic, a procedure authorized by a state emergency order, though it is unclear if the officer was sworn in during the call. Police seized methamphetamine, cocaine, firearms, and cellphones. Following his arrest, Weaver was interviewed, signed a form acknowledging his Miranda rights, and made incriminating statements. The district court later granted Weaver's motion to suppress both the physical evidence and his statements, ruling the affidavit was too conclusory and the waiver of rights was not voluntary. The government appealed this decision.
The Fifth Circuit addressed the suppression of the search evidence first. Under the good-faith exception to the exclusionary rule, evidence obtained from a warrant later found to be deficient is admissible if officers reasonably relied on the warrant. The court rejected the district court's finding that the affidavit was 'bare bones.' The opinion explains that boilerplate language does not invalidate a warrant when specific facts are present. Here, the affidavit did not merely rely on a tip; it detailed three specific controlled buys, the surveillance process, the type of drugs, the address, and the vehicle used. The court distinguished this from cases where affidavits contain only conclusory statements. Because the affidavit was sufficiently detailed, the good-faith exception applied, and the court did not need to reach the probable cause question. Regarding the magistrate's FaceTime approval, the court noted that while the procedure was irregular, the officer signed the affidavit under penalty of perjury, and penalizing the officer for the judge's procedural error does not serve the deterrence goals of the Fourth Amendment. On the issue of the statements, the court acknowledged that the district court correctly found the express waiver invalid because Officer Mittan did not read the waiver section to Weaver, creating a deceptive situation. However, the court held that the district court erred by not analyzing whether Weaver implicitly waived his rights. Under Supreme Court precedent, a waiver can be implied through a suspect's silence and conduct after understanding their rights. The Fifth Circuit declined to make this factual determination itself and remanded the issue for the district court to consider.
The evidence seized from Weaver's home, including drugs and firearms, is now admissible for trial. The case is remanded to the district court to determine if Weaver implicitly waived his Miranda rights based on his conduct during the interview. If the district court finds an implicit waiver, the statements will be admissible; if not, they will be suppressed. The decision clarifies that affidavits with specific, corroborated controlled buy details satisfy the good-faith exception, even if the magistrate's approval process involves video conferencing.
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