United States v. Philip Maccani, No. 21-2642 (8th Cir. 2022)
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Defendant pleaded guilty to one count of possession of an unregistered National Firearms Act firearm. On appeal, Defendant argued that the district court erred in denying his motion to suppress evidence obtained from the trailer he occupied. He contends that the warrant was invalid because it lacked probable cause and failed to describe with particularity the items that police intended to seize.
The Eighth Circuit affirmed. The court reasoned that the description of items found in the warrant meets the pragmatic standards imposed by the Fourth Amendment. Further, Defendant has not shown that the officers’ reliance on the warrant was objectively unreasonable. The warrant application affidavit passes muster. It was neither deceptive nor deficient. The district court did not err in admitting evidence found pursuant to the warrant.
Court Description: [Smith, Author, with Wollman and Grasz, Circuit Judges] Criminal case - Criminal law. The search warrant adequately described the items to be seized from defendant's residence; the district court did not err in concluding that even if the warrant was deficient, the search was still valid under the Leon good-faith exception as the warrant application was neither deceptive nor deficient.
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