United States v. Brown, No. 13-1761 (6th Cir. 2015)
Annotate this CaseCooperating witness, “DEA1,” provided information concerning Middleton’s heroin trafficking, including phone numbers DEA1 used to contact Middleton. DEA1 identified Middleton’s residence as the drug distribution point. DEA1 set up a controlled heroin purchase. Surveillance units noticed a Silverado parked at the residence. Middleton agreed to deliver the heroin, stating he would leave in “ten minutes” to meet DEA1. A Denali arrived at Middleton’s residence. Men left minutes later with a large, dark-colored object, which was placed in the Silverado. Both vehicles headed toward the meeting area. State police stopped the Silverado. The sole occupant was Woods, driving on a suspended license; he verbally consented to a search, which revealed a black tool case, containing a substance that field-tested as heroin. Troopers also stopped the Denali, driven by Middleton. Brown was a passenger, in possession of $4,813, cash. Officers recovered cell phones during an inventory search, including one DEA1 had used to contact Middleton. DEA obtained a warrant to search Brown’s Detroit residence. The Sixth Circuit affirmed Brown’s convictions for possession with intent to distribute marijuana, possession of a firearm in furtherance of drug trafficking, and possession of a firearm after a felony conviction. The court noted concern that the warrant affidavit supplied a tenuous nexus between drug trafficking and Brown’s residence, but concluded that the totality of the circumstances provided probable cause. The court properly admitted a “drug ledger” into evidence and excluded evidence concerning Brown’s Michigan medical marijuana license.
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