Probable Cause – Warrantless Search – Suppression of Evidence

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7^th Circuit Court of Appeals

Case Name: United States of America v. Edward Woodfork

Case No.: 20-3415

Officials: WOOD, BRENNAN, and ST. EVE, Circuit Judges.

Focus: Probable Cause – Warrantless Search – Suppression of Evidence

In 2018, a state police officer sought and obtained a warrant to search Defendant Edward Woodfork’s home based on the officer’s orchestration of several controlled-buy drug transactions involving Woodfork. Upon executing the warrant, officers discovered methamphetamine and a firearm at Woodfork’s suspected residence. Based on this evidence, a federal grand jury indicted Woodfork for possession of methamphetamine with intent to distribute and possession of a firearm by a felon.

Woodfork maintains that the officer made material misstatements or omissions in seeking the warrant in violation of Franks v. Delaware, 438 U.S. 154 (1978), and that probable cause to issue the search warrant was lacking in the first instance. Accordingly, Woodfork moved the district court to quash the search warrant and to suppress the resulting evidence. When the district court denied the motion, Woodfork pled guilty to both charges but preserved his ability to appeal the district court’s denial of his suppression motion. We affirm the district court’s denial of the motion to quash and to suppress.

Affirmed

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Derek A Hawkins is Corporate Counsel, at Salesforce.