TN: Conclusory statement from CI defs had drugs and unsuccessful controlled buy was neither PC for warrant nor RS for probation search

The trial court properly granted defendants’ motion to suppress evidence seized as a result of a warrantless search of their house. The information possessed by the officers at the time of the search, including a conclusory statement from a confidential informant and an unsuccessful attempt at a controlled buy at the home, was insufficient to establish that the female defendant, who was on probation, was engaged in illegal drug-related activity at the home. Moreover, there was no reasonable suspicion to support the search as a probation search, because the officers admitted they received vague information that defendants might be involved in drug activity and the officers were unsuccessful in an attempt to buy drugs. State v. Hamm, 2017 Tenn. Crim. App. LEXIS 711 (Aug. 11, 2017).

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