Background
Law enforcement observed Micah Gray selling methamphetamine outside his apartment and conducted controlled purchases. Officers obtained a search warrant for his apartment and later arrested him in his sister’s vehicle, finding additional evidence. A grand jury indicted Gray on drug charges, and a jury convicted him on all counts. The district court sentenced Gray to two hundred eighty-eight months in prison.
The court’s reasoning
The court held that the good-faith exception to the exclusionary rule saved the search warrants because the affidavits established a minimally sufficient nexus between the defendant’s drug activity and the locations searched. The court found that Gray failed to demonstrate systematic exclusion of African Americans in the jury selection process, failing to meet the burden for fair-cross-section claims. The court also ruled that the district court properly denied funds for a handwriting expert, as Gray offered no evidence beyond speculation that the warrants were forged.
A minimally sufficient nexus is not a high bar.
United States v. Neal, 106 F.4th 568, 572 (2024)
What it means going forward
The decision reinforces the application of the good-faith exception in drug cases where a nexus exists, even if debatable, and clarifies the high burden for proving systematic jury exclusion.