U.S. v. Bradford

Federal 7th Circuit Court
Criminal Court
Search and Seizure
Citation
Case Number: 
No. 17-1080
Decision Date: 
September 19, 2018
Federal District: 
S.D. Ill.
Holding: 
Affirmed

In prosecution on drug conspiracy and firearm charges, Dist. Ct. did not err in denying defendant’s motion to suppress evidence seized pursuant to issuance of search warrant, even though defendant argued that warrant application lacked probable cause, where warrant application relied on statements made by confidential informant, and where application omitted negative information, such as one of informant’s three prior felony convictions, informant’s probation status and payments informant had received for services as informant. Warrant was supported by probable cause in spite of said omissions, where information supplied by informant about defendant’s drug activities/possession of guns was recent and was corroborated by other witnesses and by ATF personnel. Also, Dist. Ct. did not commit plain error in admitting evidence of four uncharged incidents in which defendant directed others to shoot, rob or assault third-parties, since said evidence was relevant to help establish charged drug conspiracy, as well as rebut any claim that charged conspiracy was nothing more than buyer/seller relationship.