U.S. v. Searcy

In prosecution on charge of felon in possession of firearm, Dist. Ct. did not err in denying defendant's motion to suppress seizure of firearm found in defendant's residence pursuant to search warrant that had been supported by affidavit from confidential informant, who indicated that he had recently seen defendant in defendant's residence with firearm. While informant's affidavit lacked certain details, contents of affidavit provided sufficient reliable information to support issuance of search warrant where: (1) informant's information was obtained through first-hand observation made within 72 hours of warrant application; (2) police partially verified information supplied by informant by confirming defendant's address; (3) informant's statement that rival gang shot at defendant's home was consistent with police understanding that defendant was active member in gang that was often involved in weapons-related incidents; and (4) informant was reliable where he had provided information that led to three prior arrests in past six months.