United States v. Quwinton Norman

In United States v. Norman, 129 F.4th 874 (5th Cir. 2025), the Fifth Circuit reversed the district court’s decision to suppress evidence obtained from a house and a vehicle pursuant to a search warrant because the good-faith exception applied.

Background: A Louisiana Sheriff’s Office detective believed Norman was distributing methamphetamine from his apartment. The detective applied for and received search warrants for two locations: Norman’s apartment and “a nearby house, where Norman spent the night after the transaction.” When officers searched the house, they also searched Norman’s vehicle, which was in the garage. They found drugs, cash, and other items.

When Norman was charged with possession with intent to distribute controlled substances, he moved to suppress the evidence, “arguing that the affidavit in support of the warrant failed to establish probable cause and was bare bones.” The district court granted the motion, and the Government appealed.

Holding: The good-faith exception applies because the detective’s warrant affidavit presented sufficient facts—it was not a bare-bones affidavit—so the evidence should not have been suppressed.

Under the good-faith exception to the exclusionary rule, “evidence obtained by officers in objectively reasonable good-faith reliance upon a search warrant is admissible, even though the affidavit on which the warrant was based was insufficient to establish probable cause.” United States v. Satterwhite, 980 F.2d 317, 320 (5th Cir. 1992). But the good-faith exception does not apply if the warrant is “so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable.” Id. (quoting United States v. Leon, 468 U.S. 897, 923 (1984)).

Here, the detective’s affidavit provided Norman’s text messages showing that he was selling “large quantities of narcotics … several times a week.” In the texts, Norman told a buyer to meet him “at his apartment, his residence, and nearby locations to purchase illicit narcotics.” Moreover, after one drug transaction, officers witnessed Norman drive to the house at issue, and they never saw anyone leave that night.

Those and other facts in the affidavit were sufficient to allow officers to “reasonably rely on the state judge’s conclusion that there was a nexus between evidence of Norman’s drug trafficking and the house.” Because this was not a bare-bones affidavit, the good-faith exception applied, so the evidence should not have been suppressed.