United States v. Knutson, No. 19-1737 (8th Cir. 2020)
Annotate this CaseThe Eighth Circuit affirmed the district court's judgment after defendant pleaded guilty to possession of methamphetamine with intent to distribute. The court upheld the district court's denial of defendant's motion to suppress, holding that the district court did not err in finding there was probable cause where the affidavit was based on two highly detailed tips that were corroborated by police investigation. Furthermore, defendant has not made a substantial preliminary showing that the affiant's description of him as a tenant was false or based on a material omission or lack of investigation, and defendant has not shown that the alleged false statement or omission was necessary to the finding of probable cause. Therefore, the district court did not abuse its discretion by denying defendant's request for a Franks hearing.
Court Description: [Per Curiam - Before Smith, Chief Judge, and Melloy and Shepherd, Circuit Judges] Criminal case - Criminal law. The evidence supplied in support of the search warrant established probable cause, and an allegedly false statement that defendant was the tenant of the premises was not necessary to the finding of probable cause; without the statement there was still sufficient information to establish probable cause that there was drug activity at the premises, and the district court did not err in denying defendant's request for a Franks hearing.
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