United States v. Gordon, No. 15-2087 (1st Cir. 2017)Annotate this Case
The First Circuit affirmed the district court’s orders denying Defendant’s motion to suppress wiretap evidence and denying Defendant’s two requests for evidentiary hearings in connection with the motion to suppress. Defendant entered a conditional guilty plea to conspiracy to distribute and possess with intent to distribute controlled substances, preserving his right to appeal the denial of his motion to suppress and his related requests for evidentiary hearings. The First Circuit affirmed, holding (1) the wiretap orders were not so lacking in particularity as to demand suppression, the wiretap applications were more than minimally adequate to justify the wiretap orders, and suppression was not required due to minimization deficiencies; and (2) the district court did not abuse its discretion in declining to hold either a general evidentiary hearing or a Franks hearing.