United States v. Hueston, No. 23-1057 (7th Cir. 2024)
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The case arose from a tipster's information that led to an investigation and subsequent search of David Hueston's apartment in Marion, Indiana. The search, which was conducted under a warrant, produced drugs, cash, a gun, and ammunition. Hueston was charged with various drug-related offenses. He sought to suppress the evidence, arguing that the detectives deliberately or recklessly made misleading omissions and misrepresentations to obtain the search warrant. The district court denied Hueston's motion after conducting a Franks hearing, and Hueston appealed.
The United States Court of Appeals for the Seventh Circuit found that though the affidavit supporting the search warrant contained omissions and inaccuracies, it was not clear that the detectives acted with deliberate intent or recklessness to mislead the judge who issued the warrant. The court noted that the detectives' consultation with a prosecutor both before and after drafting the affidavit argued against a finding of intent to mislead. The court also found that the good-faith exception applied, meaning that the police officers acted in good faith reliance upon a facially valid warrant. As such, the court affirmed the district court's denial of Hueston's motion to suppress the evidence.
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