United States v. Brown, No. 13-1761 (6th Cir. 2016)
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 and set up a controlled buy. Middleton agreed to deliver the heroin, stating he would leave in “ten minutes.” A Denali arrived at Middleton’s residence. Men left minutes later with a large, dark-colored object, which was placed in a Silverado that had been parked at the residence. Both vehicles headed toward the meeting area. 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 initially affirmed, but in an amended opinion, vacated, 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 warrant affidavit supplied a tenuous nexus between drug trafficking; under the totality of the circumstances, the warrant was issued without probable cause and the good-faith exception did not apply.
This opinion or order relates to an opinion or order originally issued on September 11, 2015.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.