Suppression of Evidence

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7^th Circuit Court of Appeals

Case Name: United States of America v. David Hueston

Case No.: 23-1057

Officials: Wood, St. Eve, and Lee, Circuit Judges.

Focus: Suppression of Evidence

The case originated from information provided by a tipster, leading to an investigation and subsequent search of Hueston’s apartment in Marion, Indiana. The search, conducted with a warrant, yielded drugs, cash, a firearm, and ammunition. Hueston faced charges for various drug-related offenses and sought to suppress the evidence, contending that the detectives intentionally or recklessly omitted crucial information and misrepresented facts to secure the search warrant. The district court, following a Franks hearing, rejected Hueston’s motion, prompting his appeal.

The Seventh Circuit acknowledged that the affidavit supporting the search warrant contained omissions and inaccuracies. However, the court concluded that there was insufficient clarity to establish that the detectives had intentionally or recklessly misled the issuing judge. Notably, the court highlighted that the detectives had consulted with a prosecutor both before and after drafting the affidavit, which argued against a finding of intent to mislead. Furthermore, the court determined that the good-faith exception applied, indicating that the police officers had acted in reliance on a facially valid warrant in good faith. Consequently, the court upheld the district court’s decision to deny Hueston’s motion to suppress the evidence.

Affirmed.

Decided 01/12/24

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