U.S. v. Haynes

In prosecution on drug possession and firearm charges, Dist. Ct. did not err in denying defendant’s motion to suppress drugs and firearm seized from defendant’s home pursuant to issuance of search warrant, even though defendant argued that affidavit supporting issuance of warrant did not establish probable cause because there were no statements that established reliability of information supplied by confidential informant, who otherwise could not name defendant as culprit. Police deputies corroborated information supplied by informant by conducting their own surveillance of defendant’s home and executing their own controlled buy that involved defendant. Also, properly executed controlled drug buy can establish probable cause even when tip that prompted it might not have been credible.