What is the test for suppressing evidence seized pursuant to a search warrant?

As a preliminary issue, the government contends that some appellants lack standing to challenge the searches of certain houses. Because no factual record was made and at least one appellant has standing as to each property, we assume that all have standing. United States v. Spilotro, 800 F.2d 959, 962-63 (9th Cir. 1986).

Evidence seized pursuant to a search warrant must be suppressed if a defendant shows that the supporting affidavit contains intentionally or recklessly false statements and the affidavit, purged of its inaccuracies, is insufficient to establish probable cause. United States v. Stanert, 762 F.2d 775, 780 (9th Cir.), amended, 769 F.2d 1410 (9th Cir. 1985).

The redacted affidavit described a tip about the importation of marijuana into Tucson and, although the tip was anonymous, it was fairly detailed and, as corroborated by independent investigation, accurately predicted future events. The agents saw bags which could have concealed contraband, which was consistent with the tipster's statement that the drugs would be hidden in the bed of the truck. United States v. Angulo-Lopez, 791 F.2d 1394, 1399 (9th Cir. 1986) ("Direct evidence that contraband or evidence is at a particular location is not essential to establish probable cause to search the location.").