United States v. Calligan, No. 20-1817 (7th Cir. 2021)
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DHS Agent Goehring obtained a warrant for Calligan's girlfriend's Fort Wayne house. His supporting affidavit reported that, 10 days earlier, customs agents had intercepted a package containing one kilogram of a synthetic cannabinoid controlled substance (5F‐ADB), addressed to that house, with Calligan as the addressee. Calligan had received more than 50 international shipments there. Calligan had Indiana convictions for attempted murder, criminal recklessness, and unlawfully resisting police, and a pending gun possession charge. Although police delivered the package, agents had replaced the controlled substance with sugar. After Calligan accepted the package, the officers executed the warrant and found money, a gun, and a notebook that contained the package’s tracking number and a recipe for making 5F‐ADB into a consumable product. In the warrant return, Goehring inaccurately reported that police had also recovered 5F‐ADB, the package’s original contents.
The Seventh Circuit affirmed Calligan’s convictions for possessing a firearm as a felon, importing a controlled substance, and attempting to distribute a controlled substance. The court rejected arguments that because the warrant application said police would deliver actual drugs, the agent’s replacement of the drugs with sugar took the search outside the warrant’s scope and that Goehring’s warrant application relied on materially false representations that police would deliver drugs to the home before the search. The warrant was supported by probable cause and had no triggering condition and, in any event, police relied on it in good faith.
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