United States v. Woodfork, No. 20-3415 (7th Cir. 2021)Annotate this Case
Danville Officer Crawley sought a warrant to search Woodfork’s home. Crawley testified under oath, identifying Woodfork as the target of the request, stating that Woodfork had sold crystal methamphetamine in a controlled buy to a confidential source (CS) that day. Officers had searched the SC before and after that buy and surveilled the transaction, which was recorded. Crawley had relied on the CS “multiple times” and found him “reliable.” The officers attempted to set up a second controlled buy, using another reliable CS. Woodfork had insisted that the CS come to Woodfork’s home, which was described by naming an intersection, understood to be 1220 North Franklin Street.
The judge issued a search warrant for Woodfork’s North Franklin home. Officers discovered methamphetamine and a firearm. Woodfork moved to quash the warrant and or to suppress the evidence, arguing that he was entitled to a "Franks" hearing and suppression because Crawley misled the county judge regarding the identification of his home and by omitting details about the CS's criminal histories.
The Seventh Circuit affirmed the denial of Woodfork’s motion. Crawley and the judge were not simply relying on the uncorroborated word of the CS; a controlled buy, properly executed, is generally a reliable indicator of the presence of illegal drug activity. The omission of information about the sources’ backgrounds, criminal histories, or motives does not change the probable cause determination. Crawley testified; the court could assess his credibility and ask questions.