United States v. Sanford, No. 20-2691 (7th Cir. 2022)
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Officer Stringer and a confidential informant (Hinkle) appeared before a state court judge and obtained a warrant. Following the ensuing search, Sanford was charged with possession of heroin with intent to distribute. 21 U.S.C. 841(a)(1) & (b)(1)(C), possession of a firearm in furtherance of a drug-trafficking crime, 924(c)(1)(A)(i), and possession of a firearm as a felon, 922(g)(1). Sanford sought to challenge the warranted search and sought a “Franks” hearing. Sanford presented Hinkle’s Declaration that officers told her that if she did not cooperate they would take away her one-year-old daughter, that she would not be charged with any new offenses, that an outstanding warrant for failure to appear in a misdemeanor case would be “taken care of,” and that she should state that she had not been promised anything for testifying. . The government informed the court that FBI agents had discussed Hinkle’s Declaration with her and that she told them she did not prepare the Declaration and that much of it was false or essentially untrue.
After a "pre-Franks" hearing, the district court upheld the search. The Seventh Circuit affirmed. Warrant-issuing judges are aware that confidential informants are likely to have criminal histories; Hinkle admitted to criminal conduct. The district court did not err in determining that a Franks hearing was not necessary based solely on the failure to discuss Hinkle’s “unremarkable” criminal history.
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