The Supreme Court set a reasonable standards test for affidavits seeking a search warrant.
THE CRIME: On May 7, 2012, a witness reported that LaDream Hampton Yarbrough brandished a handgun at a woman in a St. Paul park and threatened her for stealing “a large amount” of his crack cocaine. Yarbrough then left the scene in a maroon Chevrolet Caprice bearing a specified Minnesota license plate number. A woman drove the car.
Using databases, Saint Paul police officers discovered that Yarbrough and his female roommate lived in an apartment on West 7th Street. Officers observed the maroon Chevrolet Caprice with the specified license plate number parked at the rear of the apartment building. The vehicle was registered to Yarbrough’s roommate at that address.
Officers also learned from a confidential reliable informant that Yarbrough was a known dealer of crack cocaine and carried a handgun. Yarbrough had been arrested on February 14, 2012, for possession of a controlled substance with intent to distribute. At the time of that arrest, Yarbrough’s roommate was with him in the same maroon Chevrolet Caprice.
Based on this information, on May 10, 2012, officers applied for a warrant to search Yarbrough, the maroon Chevrolet Caprice, and the apartment. That same day, a Ramsey County judge issued the warrant. Among other things, the warrant authorized the officers to search the apartment for firearms, ammunition, papers showing control of the residence, and controlled substances.
The next day officers arrested Yarbrough. Then they executed the search warrant at the apartment. During the search, officers recovered a large amount of cash, a silver handgun with a black grip that was later determined to be stolen, ammunition, and drugs.
The State charged Yarbrough in Ramsey County District Court with felony possession of
cocaine; felony possession of marijuana; and receipt of stolen property (the handgun).
Before trial, Yarbrough filed a written motion to suppress evidence, including evidence seized from the apartment. The district court granted Yarbrough’s motion to suppress the evidence from the apartment on the ground that the search warrant affidavit failed to establish a sufficient nexus between Yarbrough’s alleged criminal activity and the apartment.
Because the district court’s order suppressing the gun and drug evidence from the apartment had a critical impact on the State’s case, the State appealed.
The Minnesota Court of Appeals reversed, stating that it was reasonable to infer that Yarbrough would keep at the apartment the handgun used in the May 7 confrontation. The court of appeals therefore held that the handgun information in the search warrant affidavit established probable cause to search the apartment for gun evidence. Without reaching the nexus issue regarding the drug information in the search warrant affidavit, the court of appeals applied the plain view doctrine and ruled that the drug evidence was admissible.
On January 8, 2014, the Supreme Court held that the affidavit for the warrant was reasonable, the search warrant was valid, the apartment evidence was admissible, and the case was returned to the district court for resolution. See here.
The Supreme Court held: "Because the information in the search warrant affidavit established a sufficient nexus between appellant’s criminal activity and the residence to be searched, the judge issuing the warrant had a substantial basis to find probable cause that handgun and drug
evidence would be found at the residence."
THE CRIME: On May 7, 2012, a witness reported that LaDream Hampton Yarbrough brandished a handgun at a woman in a St. Paul park and threatened her for stealing “a large amount” of his crack cocaine. Yarbrough then left the scene in a maroon Chevrolet Caprice bearing a specified Minnesota license plate number. A woman drove the car.
Using databases, Saint Paul police officers discovered that Yarbrough and his female roommate lived in an apartment on West 7th Street. Officers observed the maroon Chevrolet Caprice with the specified license plate number parked at the rear of the apartment building. The vehicle was registered to Yarbrough’s roommate at that address.
Officers also learned from a confidential reliable informant that Yarbrough was a known dealer of crack cocaine and carried a handgun. Yarbrough had been arrested on February 14, 2012, for possession of a controlled substance with intent to distribute. At the time of that arrest, Yarbrough’s roommate was with him in the same maroon Chevrolet Caprice.
Based on this information, on May 10, 2012, officers applied for a warrant to search Yarbrough, the maroon Chevrolet Caprice, and the apartment. That same day, a Ramsey County judge issued the warrant. Among other things, the warrant authorized the officers to search the apartment for firearms, ammunition, papers showing control of the residence, and controlled substances.
The next day officers arrested Yarbrough. Then they executed the search warrant at the apartment. During the search, officers recovered a large amount of cash, a silver handgun with a black grip that was later determined to be stolen, ammunition, and drugs.
The State charged Yarbrough in Ramsey County District Court with felony possession of
cocaine; felony possession of marijuana; and receipt of stolen property (the handgun).
Before trial, Yarbrough filed a written motion to suppress evidence, including evidence seized from the apartment. The district court granted Yarbrough’s motion to suppress the evidence from the apartment on the ground that the search warrant affidavit failed to establish a sufficient nexus between Yarbrough’s alleged criminal activity and the apartment.
Because the district court’s order suppressing the gun and drug evidence from the apartment had a critical impact on the State’s case, the State appealed.
The Minnesota Court of Appeals reversed, stating that it was reasonable to infer that Yarbrough would keep at the apartment the handgun used in the May 7 confrontation. The court of appeals therefore held that the handgun information in the search warrant affidavit established probable cause to search the apartment for gun evidence. Without reaching the nexus issue regarding the drug information in the search warrant affidavit, the court of appeals applied the plain view doctrine and ruled that the drug evidence was admissible.
On January 8, 2014, the Supreme Court held that the affidavit for the warrant was reasonable, the search warrant was valid, the apartment evidence was admissible, and the case was returned to the district court for resolution. See here.
The Supreme Court held: "Because the information in the search warrant affidavit established a sufficient nexus between appellant’s criminal activity and the residence to be searched, the judge issuing the warrant had a substantial basis to find probable cause that handgun and drug
evidence would be found at the residence."
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