CA6: Where def refused to provide combination to his safe during execution of a SW, it was reasonable to pry it open

Defendant showed the police that he had marijuana inside his home and the police obtained a warrant to search his home. Thus, suppression was not warranted because there was an outright certainty, not just a “fair probability,” that the house contained illegal drugs, and it did not matter whether the police suspected that he possessed marijuana, dealt marijuana, or committed some other crime. The contents of the warrant affidavit were not “stale,” because the affidavit provided every reason for the magistrate to think there were drugs in the house at the time the warrant was issued. The police did not act unreasonably when they used a prying ram to open defendant’s safe, because they had probable cause to believe there might be drugs inside and defendant refused to provide the safe’s combination. United States v. Church, 2016 U.S. App. LEXIS 8982 (6th Cir. May 17, 2016).