United States v. Seidel, No. 11-2490 (8th Cir. 2012)
Annotate this CaseDefendant entered a conditional guilty plea to conspiracy to possess with intent to distribute and distribute controlled substance. On appeal, defendant challenged the district court's denial of his motion to suppress evidence obtained through a search warrant, arguing that the warrant, based on a garbage pull conducted at his residence, was issued without probable cause. In the present case, the court had little hesitancy in concluding that a reasonable magistrate would conclude the materials found in the trash - nine spiral bound notebook pieces of paper that had ledgers on them, a syringe, and a metal paper clip that tested positive for marijuana - were sufficient to establish probable cause that defendant's residence and garage contained controlled substances, drug paraphernalia, pay sheets, currency, cellular telephones, and any other indicia of drug trafficking. The court also held that the deputy's recorded, sworn oral testimony was sufficient to support the issuance of the warrant and affirmed the judgment.
Court Description: Criminal Case - suppression. Warrant based on a garbage pull conducted at residence which found pay-owe sheets, a syringe, and a paper clip that tested positive for marijuana was sufficient for a finding of probable cause and district court did not err in denying motion to suppress fruits of search of residence and garage. District court did not err in relying on oral testimony of officer, in that testimony was duly sworn and recorded.
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