United States v. Coleman, No. 18-1083 (6th Cir. 2019)Annotate this Case
During an investigation of Powell, a drug dealer, a cooperating defendant identified one of Powell's sources as Coleman. Officers observed Coleman’s automobiles, a Trailblazer and an Enclave, in connection with suspected drug sales to Powell. On April 7, 2017, officers observed an individual matching Coleman’s description arrive at Powell’s house, exit Coleman’s Enclave, enter the house, and leave three minutes later. Four days later, Coleman arrived at Powell’s house in the Trailblazer and sold cocaine to the cooperating defendant. Officers determined Coleman had two felony convictions for delivery or manufacture of a controlled substance and that both vehicles were registered to Coleman’s father. A magistrate issued tracking warrants for Coleman’s vehicles. An ATF agent attached the tracking devices to Coleman’s vehicles on the shared driveway adjoining Coleman’s condominium. There is no gate or fence at the complex entrance; anyone can drive into the complex unimpeded. On May 10, agents observed Coleman leave his condo, enter the Enclave, and exit the Enclave at Powell’s home and watched the GPS tracking data showing that Coleman traveled directly from his condo to Powell’s house. Agents obtained a warrant to search Coleman’s condo and seized 500 grams of cocaine, a firearm, and documents and property indicating money laundering. Coleman admitted ownership of the cocaine and a firearm.
Coleman unsuccessfully moved to suppress the fruits of the search warrants. The Sixth Circuit upheld Coleman’s conviction and 120-month sentence. The warrant was supported by probable cause; Coleman’s driveway was not within the curtilage of his home; the residential search warrant was supported by probable cause; and even if the warrants were not supported by probable cause, ATF agents executed them in good faith.