United States v. Arnold, No. 12-3082 (8th Cir. 2013)
Annotate this CaseDefendant appealed the district court's denial of his motion to suppress evidence from a search that led to his arrest for drug and firearm possession charges, and motion for a hearing to challenge the truthfulness of the factual statements in the application for the search warrant. The court agreed with the district court that many of defendant's challenges highlight, at most, minor discrepancies or omissions that do not establish deliberate or reckless falsehood. Even for those few instances where the district court agreed with defendant that the affidavit contained a misrepresentation, defendant provided no evidence suggesting that the misrepresentations were deliberate or reckless. Finally, even if the court were to assume the challenged affidavit contained deliberate or reckless falsehoods, defendant's arguments for a Franks v. Delaware hearing would still fail because the affidavit established probable cause even absent any misrepresentations and including the omitted information at issue. Accordingly, the court affirmed the judgment.
Court Description: Criminal case - Criminal law. Defendant's challenges to the search warrant application amounted, at most, to minor discrepancies that did not establish deliberate or reckless falsehood, and the district court did not err in denying his motion for a Franks hearing; even if the court assumed the challenged affidavit contained deliberate or reckless falsehoods, the unchallenged portions of the affidavit established probable cause.
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