United States v. Lyles, No. 17-4787 (4th Cir. 2018)Annotate this Case
Law enforcement officers obtained a warrant to search defendant's home after they found three marijuana stems in a trash pull. The Fourth Circuit affirmed the district court's grant of defendant's motion to suppress evidence found in his home, holding that the trash pull evidence did not adequately support the warrant to search defendant's home for marijuana possession. The court explained that the affidavit did not provide a substantial basis for the magistrate to find probable cause to search the home for evidence of marijuana possession, and the warrant provided search and seizure authority wholly disconnected from marijuana possession. The court declined to apply the Leon good faith standard.