Background
Law enforcement officers seized drugs, firearms, and cash during a search of Johnny Barbour’s home based on a warrant signed by a state judge. Barbour moved to suppress the evidence, arguing the warrant lacked probable cause. The district court denied the motion, finding the officers acted in good faith despite the warrant’s defects. Barbour pleaded guilty and appealed the denial of his suppression motion.
The court’s reasoning
The court reviewed the affidavit and found it was not bare bones because it contained a minimally sufficient nexus connecting the defendant’s drug activity to the residence. The affidavit included observations from a confidential informant and dates that supported a reasonable inference of recent activity. The court also found no evidence of systemic negligence by the Coffee County Sheriff’s Department, as the record showed only a single instance where omitted information led to a lack of probable cause.
The affidavit detailed the investigation into Barbour’s suspected drug dealing: a confidential informant told officers that a black male subject named Johnny was selling methamphetamine out of the Helen Street residence, and a confidential informant subsequently twice observed drug transactions inside the Helen Street residence.
Opinion at 4
What it means going forward
The decision reinforces that the good-faith exception can save evidence even when a warrant is defective, provided the affidavit is not bare bones and there is no systemic police negligence.