Michael Shaun Davis was indicted for possessing a firearm and ammunition as a convicted felon, a violation of 18 U.S.C. § 922(g)(1). The evidence against him was seized during a search of his home in Eufaula, Oklahoma, based on a warrant obtained by a sheriff's investigator. The warrant listed the address as 10 McGinnis Street, but Davis argued the correct address was 10 Meginnis Street. Davis moved to suppress the evidence, claiming the warrant violated the Fourth Amendment's particularity requirement because it listed a nonexistent address. The district court found the correct address unclear and, assuming the warrant was incorrect, held that the good-faith exception still applied. Davis pleaded guilty but reserved his right to appeal the suppression ruling.
The Tenth Circuit focused on the good-faith exception to the exclusionary rule, established in United States v. Leon. The court explained that the exclusionary rule is designed to deter police misconduct, not to remedy errors by magistrates. The court reviewed the totality of the circumstances to determine if the officers' conduct was sufficiently culpable to warrant suppression. The record showed that the investigator who obtained the warrant reasonably relied on county assessor records to determine the address. Furthermore, a deputy executing the warrant testified that he knew exactly where Davis lived because he had been to the house before. The court rejected Davis's argument that any reasonable officer would have realized the address was wrong, noting that the district court itself remained unsure whether the street name was McGinnis or Meginnis. The court distinguished this case from United States v. Williamson, where the warrant provided no meaningful description of the premises. Here, the warrant was not so facially deficient that executing officers could not reasonably presume it to be valid. The court also noted that Davis waived a new argument regarding improper execution of the warrant by raising it for the first time in his reply brief.
The firearms evidence seized from Davis's home remains admissible for his felony possession trial. The decision reinforces that clerical errors in warrants, particularly those involving street names where the location is otherwise identifiable, will not trigger the exclusionary rule if officers acted in good faith. The ruling clarifies that the good-faith exception applies unless a warrant is so facially deficient that a reasonable officer would know it is invalid. No remand instructions were issued as the judgment was affirmed.
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