United States v. Helton, No. 21-5144 (6th Cir. 2022)
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After going to Helton’s home to execute a warrant for his arrest, Knox County Deputy Mullins sought a search warrant. His affidavit stated that Mullins had received complaints about Helton selling methamphetamine; that a reliable source advised that a person he was with purchased methamphetamine at the residence; and that when the officers arrived Helton had a clear baggie that appeared to hold residue. Executing the search warrant, deputies found illegal drugs, currency, and multiple firearms. Deputies then obtained a warrant and searched the home of Helton’s mother, recovering money, firearms, and drugs.
Helton was charged with conspiracy to distribute methamphetamine, possession with intent to distribute methamphetamine, and being a felon in possession of firearms. The court rejected motions to suppress, upholding both warrants. At trial, Moore testified about a controlled purchase of methamphetamine from Helton. Juror 191 told the judge that she recognized Moore as someone that she would watch during her employment at a shopping center “in case she was going to steal,” but that she was not aware of Moore actually shoplifting. Over Helton’s opposition, the district court struck Juror 191 on the basis that she personally knew Moore and had twice responded “I think so” when asked if she could set aside her knowledge of Moore. The Sixth Circuit upheld Helton’s convictions and 264-month sentence. While the search warrant did not satisfy constitutional requirements, the good-faith exception to the exclusionary rule applied.
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