Suppression of Evidence – Good Faith Exception

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7^th Circuit Court of Appeals

Case Name: United States of America v. Kyle S. Matthews

Case No.: 20-2686

Officials: RIPPLE, HAMILTON, and KIRSCH, Circuit Judges.

Focus: Suppression of Evidence – Good Faith Exception

The Clinton County, Illinois, Sheriff’s Office executed a search warrant on a property where Kyle Matthews lived in a camper trailer. The warrant authorized the police to search every structure on the premises in the belief that Mr. Matthews lived on and had access to the whole property. The Sheriff’s Office, however, had not offered the issuing judge much information to substantiate this belief.

The evidence found during the search led to a federal indictment, and Mr. Matthews moved to exclude the fruits of the search. The district court held that the warrant was not supported by probable cause to believe that any of the suspected crimes were linked to the property. The district court nevertheless concluded that the good-faith exception to the exclusionary rule applied and therefore denied the motion to suppress. Mr. Matthews pleaded guilty to possessing an unregistered short-barreled rifle that had been found at his home, but he conditioned his plea on an appeal of the denial of the motion to suppress the evidence.

We affirm the judgment of the district court. An objectively reasonable officer, having consulted with the State’s Attorney in the preparation of the complaint and affidavit accompanying the application for the warrant, could have relied in good faith on the search warrant that he obtained from a judge. The warrant here, although incomplete, was not so utterly lacking in indicia of probable cause that suppression is justified.

Affirmed

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Derek A Hawkins is Corporate Counsel, at Salesforce.