United States v. Jones, No. 18-4671 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's motion to suppress various ammunition and ammunition components seized from his residence pursuant to a search warrant.
The court held that the search warrant was supported by probable cause. In this case, the warrant affidavit provided the magistrate with a substantial basis to conclude that defendant made terrorist threats within the meaning of W. Va. Code 61-6-24, and that evidence of this crime would be found in his home. The court also held that the alleged omissions in the warrant affidavit were immaterial to the magistrate's probable cause determination. In this case, defendant failed to demonstrate that the omitted statements were material to the magistrate's probable cause determination and thus the district court did not err in denying defendant's request for a Franks hearing.