United States v. Reed, No. 20-5631 (6th Cir. 2021)
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Memphis Officers suspected Reed of distributing marijuana. Reed had prior drug convictions. Detective Evans filed affidavits seeking search warrants for OK Tire, Orchi Road, and Bond Road. At OK Tire, owned by Reed's girlfriend, a reliable confidential informant had made a controlled buy from Reed and had seen Reed “selling and storing marijuana.” Evans had surveilled the couple leaving their home (Bond Road) and traveling to OK. Each had keys to the business. Reed’s mother lived on Orchi Road. Reed’s driver’s license listed it; Evans had watched the informant make a controlled buy from Reed there. Evans sought a warrant to search Bond Road for financial records and drug proceeds (not for drugs).
A state judge issued three search warrants. Officers seized nothing from OK and only baggies and a digital scale from Orchi Road. The search at Bond Road uncovered guns, ammunition, 18.7 grams of marijuana, 2.1 grams of THC wax, and $5,636 in cash. Reed confessed that the guns and drugs were his and that he had been selling marijuana. He later successfully moved to suppress the evidence obtained from at Bond Road, including his statements.
The Sixth Circuit reversed, declining to address the constitutional question of whether, when officers have probable cause to arrest a suspect, they need additional evidence of a “nexus” between the drug dealing and the dealer’s home in order to search that home. Even when a search violates the Fourth Amendment, courts should not suppress evidence if the police reasonably relied on a judge’s decision that probable cause justified a warrant.
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