United States v. Mayweather, No. 19-2909 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed the district court's denial of defendant's motion to suppress and motion for a Franks hearing after he was convicted of one count of possession with intent to distribute cocaine base and cocaine. In regard to the motion to suppress, the court concluded that, even if the warrant affidavit lacked probable cause, the good faith exception applies in this case because the issuing judge could have logically inferred that defendant stored contraband at his residence. Therefore, the officer's reliance on the search warrant was objectively reasonable. In regard to the motion for a Franks hearing, the court also concluded that defendant has not made a substantial preliminary showing that the statements at issue were false and defendant waived his GPS-related argument.
Court Description: [Smith, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law. The evidence seized at defendant's residence was admissible under the Leon good-faith exception as the issuing judge could have logically inferred that defendant stored contraband at his home, and the executing officer's reliance on the search warrant was objectively reasonable; the district court did not err in denying defendant's post-verdict motion for a Franks hearing as defendant did not show the contested statements in the search warrant application were false; the court did not err in finding a separate Franks argument concerning the omission of information about GPS activities was waived because it was not raised in a timely manner.
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