United States v. Santana-Dones, No. 17-1930 (1st Cir. 2019)Annotate this Case
In this consolidated appeal, the First Circuit held that the district court did not err in concluding that the court that issued a wiretap warrant could have found the facts in the application to be at least minimally adequate to support the issuance of the warrant, thus affirming the judgments below.
A federal grand jury handed up an indictment charging all four defendants in this consolidated appeal with conspiracy to distribute and to possess with intent to distribute heroin and cocaine and distribution and possession with intent to distribute heroin and/or cocaine. The four defendants eventually pleaded guilty to all charges. On appeal, the defendants challenged the district court's ruling on the motion to suppress wiretap evidence. The First Circuit affirmed, holding that the district court did not err in concluding that the wiretap application, read in tandem with its supporting affidavit, was more than minimally adequate to support the wiretap authorization.