Can a search warrant obtained pursuant to a state warrant be suppressed if the initial state warrant is invalid?

MultiRegion, United States of America

The following excerpt is from United States v. Stacy, 19-339-cr (2nd Cir. 2020):

Stacy contends that the evidence obtained pursuant to the state warrant and all the evidence that followed, including the evidence obtained pursuant to the federal warrant, should have been suppressed because the initial state warrant was invalid. The fruits of a search conducted pursuant to a warrant that issued without probable cause, however, will not be suppressed if the officers reasonably relied on the warrant in good faith. United States v. Leon, 468 U.S. 897, 920 (1984). An officer's reliance on a search warrant is unreasonable where: (1) the judge who issued the warrant was purposefully misled; (2) the judge who issued the warrant "wholly abandoned his judicial role"; (3) the affidavit accompanying the warrant application is "so lacking in indicia of probable cause as to render official belief in its existence entirely unreasonable"; or (4) the warrant is so "facially deficient . . . that the executing officers cannot reasonably presume it to be valid." Id. at 923. Though "most searches conducted pursuant to a warrant" fall within the good-faith exception, the government nevertheless bears the burden of demonstrating that officers were objectively reasonable in relying on an invalid warrant. United States v. Clark, 638 F.3d 89, 100 (2d Cir. 2011).

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