United States v. Jack Leroy Goody
Docket: 04-1190
Court: Court of Appeals for the Eighth Circuit; July 23, 2004; Federal Appellate Court
Jack Leroy Goody, the appellee, pleaded not guilty to conspiracy to manufacture and distribute methamphetamine and sought to suppress evidence obtained from a search warrant executed on his property. The district court granted his motion, concluding the affidavit lacked probable cause because the information was stale. The affidavit included statements from a witness, Joseph Finke, who claimed he had manufactured methamphetamine with Scott Tucker in an outbuilding on Goody's property in 2001 and that Goody was aware of the operation. The court noted a significant time lapse since Finke's last association with Tucker in January 2002, leading to its decision that the information was outdated. Additionally, the court found the surveillance evidence insufficient as it did not explicitly connect Tucker's visits to the outbuilding. The Eighth Circuit Court of Appeals reviewed the case, applying a clear error standard to the district court's factual findings and a de novo standard for legal conclusions regarding the Fourth Amendment and the applicability of the good-faith exception established in *United States v. Leon*. The appellate court disagreed with the district court's assessment of staleness, suggesting that the evidence was still relevant and constituted probable cause. Ultimately, the court reversed the suppression ruling, asserting that the executing officers had acted reasonably in relying on the warrant. Evidence obtained under an invalid search warrant may not be excluded if the officers acted with objective good faith in relying on the issuing magistrate's probable-cause determination, as established in Leon v. United States. The test for objective good faith assesses whether a reasonably well-trained officer would recognize the search as illegal despite the magistrate's authorization. If an affidavit is significantly lacking in probable cause, reliance on it cannot be deemed in good faith. In this case, the court found no indication of a lack of good faith by the officers, despite Mr. Goody's argument regarding the time elapsed between Mr. Finke's methamphetamine manufacturing and the search warrant issuance. The affidavit contained sufficient information, including suspicious activities involving Mr. Tucker on the property within the sixteen-month period, to support the officers' good faith. While acknowledging that good faith cannot be a blanket defense for all police actions, the court concluded that the exception applied here, leading to the reversal of the district court's order to suppress the evidence.