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Eighth Circuit
United States v. Ralston: Whether the requirements of the “Leon Good Faith” exception were meet where officers executed a search warrant on the suspect’s property, and also that of a nearby neighbor

Eight Circuit
United States v. Ralston, No. 22-3352 (8th Cir. 2023)
In this case the United States Court of Appeals for the Eight Circuit ruled that the “Leon Good Faith” exception did not apply to the execution of a search warrant of the residence of a suspect’s neighbor.

Factual Background:
Appellant Ralston lived on family property that contained two residences bisected by a road. A mobile home was located on the north side of the road and a single-family residence sat on the south side. Law enforcement officers believed Colton Varty resided in the mobile home and Ralston resided in the single-family home. Investigators identified Varty as a suspect in multiple burglaries. After developing information indicating Varty could be storing stolen items on the property, law enforcement applied for a search warrant. The affidavit contained extensive information regarding Varty’s alleged involvement in burglaries of unoccupied buildings and construction trailers. Further, the affidavit also outlined information leading law enforcement to “suspect and have probable cause to believe, Varty has committed multiple crimes of [this] nature in proximity to Ralston’s residence.” Based on this alone, the warrant authorized the search of Ralston’s residence in addition to the mobile home where Varty resided.
Following a search of his residence, Ralston was charged with being a prohibited person in possession of a firearm, in violation of 18 U.S.C. §§ 922(g) and 924(a)(2).

At issue is the validity of the search of Ralston’s residence located on the south side of the property. Ralston contends the warrant did not demonstrate a sufficient nexus between him and Varty to establish probable cause that evidence would be located inside his house.

Analysis:
The Supreme Court has held the exclusionary rule should not be applied to bar the admission of “evidence obtained by officers acting in reasonable reliance on a search warrant issued by a detached and neutral magistrate,” even if that search warrant is later determined to be invalid. United States v. Leon. In assessing whether an officer relied in good faith on the validity of a warrant, a reviewing court considers the totality of the circumstances, including any information known to the officer but not included in the affidavit. But, an officer’s reliance on a search warrant is objectively unreasonable in four instances:

(1) when the affidavit or testimony in support of the warrant included a false statement made knowingly and intentionally or with reckless disregard for its truth, thus misleading the issuing judge;

(2) when the judge ‘wholly abandoned his judicial role in issuing the warrant;

(3) when the affidavit in support of the warrant was ‘so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable’; and

(4) when the warrant is ‘so facially deficient’ that the executing officer could not reasonably presume the warrant to be valid.
At issue is the third instance—that is, whether the supporting affidavit was so lacking in indicia of probable cause that no reasonable officer would have relied upon a warrant that was issued based on it.

The court concluded that the search of defendant’s residence was not saved by the Leon Good Faith exception as no reasonable officer would believe that there was a fair probability that evidence of another man’s burglaries would be found in the defendant’s residence; the officers knew the men maintained separate residences on the property and they offered little more than a hunch that defendant’s residence was being used to store property stolen by the other man. The court concluded that without evidence that Varty had access to Ralston’s residence or facts pointing to a fair probability that Ralston’s residence contained stolen property or was being used to fence stolen property, the Leon Good Faith exception could not apply. The case was remanded to the district court with directions to grant his motion to suppress.

For the Court’s Opinion: United States v. Ralston, No. 22-3352 (8th Cir. 2023)

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